Hill et al v. Amentum Services, Inc.

Filing 19

ORDER granting 18 Motion to Extend Time for Discovery. Discovery due by 10/30/2024. Signed by Magistrate Judge Brenda Weksler on 8/29/2024. (Copies have been distributed pursuant to the NEF - CT)

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Eric B. Myers, SBN 8588
Sarah Grossman-Swenson, SBN 11979
MCCRACKEN, STEMERMAN & HOLSBERRY, LLP
1630 S. Commerce Street, Suite A-1
Las Vegas, NV 89102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiffs Jonathan Hill and Phillip Rowton
PAUL T. TRIMMER, ESQ.
Nevada Bar No. 9291
THOMAS W. MARONEY, ESQ.
Nevada Bar No.13913
JACKSON LEWIS P.C.
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Amentum Services, Inc

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JONATHON HILL, an individual, and
PHILLIP ROWTON, an individual,

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Case No. 2:23-cv-01750-MMD-BNW

Plaintiffs,

STIPULATION AND ORDER TO
EXTEND TIME FOR DISCOVERY

vs.

(FIRST REQUEST)

AMENTUM SERVICES, INC., and Does 1-10,

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Defendants.

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Defendant Amentum Services, Inc, (“Defendant”) by and through its counsel, the law firm

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of Jackson Lewis P.C., and Plaintiffs Jonathon Hill and Phillip Rowton (“Plaintiffs”), by and through

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their counsel, McCracken, Stemerman & Holsberry, LLP, hereby stipulate and agree to extend the

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deadline to complete discovery to October 30, 2024. This Stipulation is submitted and based upon

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the following:
1.

On October 27, 2023, Plaintiffs filed a Complaint naming Amentum Services, Inc,

as Defendant.

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2.

On October 31, 2023, Plaintiffs served Defendant with a copy of the Summons and

Complaint.

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3.

On January 5, 2024, Defendant filed its Motion to Dismiss Plaintiff’s Complaint.

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4.

On April 1, 2024, the Court denied Defendant’s Motion to Dismiss. ECF No. 14.

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The Court gave the Parties 180 days to complete discovery, to Saturday, September 28, 2024

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(September 30, 2024).

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5.

Amentum’s counsel was injury shortly thereafter, requiring an extension of time to

answer the complaint. Pursuant to stipulation, Defendant answered on May 1, 2024.
6.

Pursuant to Local Rule 26-3, the Parties submit the following statements:
a. Discovery completed: The Parties timely completed initial disclosures, and
they have served written discovery requests on each other, including requests
for production of documents and interrogatories. They have provided
extensions on discovery deadlines due to the schedules of counsel.
Defendants responded to Plaintiffs’ discovery on August 12, 2024, and
Plaintiffs’ responses are due on September 14, 2024.
b. Discovery that remains to be completed: The Parties need additional time
to meet and confer regarding the discovery responses and to take depositions.
Plaintiffs intend to depose Defendant’s 30(b)(6) representative, and
Defendant intends to depose Plaintiffs.

The Parties are negotiating

deposition dates.

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c. Reasons why deadline was not completed: The Parties have been working

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diligently to obtain discovery and additional time is needed to complete

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discovery prior to September 28, 2024, due to the schedules of the parties

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and counsel in September.

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d. Proposed schedule:

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i. Discovery cut-off of October 30, 2024

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ii. Written discovery completed by September 14, 2024

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iii. Depositions completed by October 14, 2024

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iv. Follow-up completed by October 28, 2024

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7.

This is the first request for an extension of time to complete discovery and is made

more than 21 days in advance of the current discovery cut-off on September 28, 2024.
8.

This request is made in good faith and not for the purpose of delay. The Parties

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have been working diligently to obtain discovery and additional time is needed to complete

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discovery due to the schedules of the parties and counsel.

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DATED this 28th day of August, 2024.
McCracken, Stemerman & Holsberry, LLP

JACKSON LEWIS P.C.

/s/ Sarah Grossman-Swenson
Sarah Grossman-Swenson, SBN 11979
1630 S. Commerce Street, Suite A-1
Las Vegas, NV 89102
Email: [e-mail]

/s/ Paul Trimmer
PAUL T. TRIMMER, ESQ.
Nevada Bar No. 9291
THOMAS W. MARONEY, ESQ.
Nevada Bar No. 13913
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101

Attorneys for Plaintiffs

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Attorneys for Defendant

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ORDER
IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

August 29, 2024
Dated: _____________________________

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