King v. Amazon.com Services, LLC
Filing
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ORDER Granting 29 Stipulation To Extend Discovery Deadline. Discovery due by 5/19/2025. Motions due by 6/17/2025. Proposed Joint Pretrial Order due by 7/17/2025. Signed by Magistrate Judge Maximiliano D. Couvillier, III on 1/28/2025. (Copies have been distributed pursuant to the NEF - ASB)
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Z. Kathryn Branson, Esq.
Nevada Bar No. 11540
Amanda M. Browder, Esq.
Pro Hac Vice Admitted
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169.5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
kbranson@littler.com
abrowder@littler.com
Attorneys for Defendant
AMAZON.COM SERVICES LLC
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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CARRIEL KING,
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Plaintiff,
v.
AMAZON.COM SERVICES LLC; and DOES
1-50, inclusive,
Case No. 2:24-cv-01499-RFB-MDC
STIPULATION AND PROPOSED
ORDER TO EXTEND DISCOVERY
DEADLINES
(FIRST REQUEST)
Defendants.
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Pursuant to Local Rule IA 6-1 and Local Rule 26-3, Defendant AMAZON.COM
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SERVICES LLC (“Defendant”) and Plaintiff CARRIEL KING (“Plaintiff”) (collectively, the
“Parties”) stipulate to amend the Discovery Plan and Scheduling Order (ECF No. 23) by extending
the outstanding discovery deadlines for a period of ninety (90) days.
This is the first request for an extension to the Discovery Plan and Scheduling Order in this
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matter. The requested extension is sought in good faith and not for purposes of undue delay. This
request is submitted at least twenty-one (21) days or more before the expiration of the subject
deadlines.
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LITTLER MENDELSON,
P.C.
3960 Howard Hughes Pkwy
Suite 300
Las Vegas, NV 89169.5937
702.862.8800
4908-4882-2288
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DISCOVERY COMPLETED
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The parties have each exchanged their initial disclosures, propounded written discovery,
and issued initial deposition notices.
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DISCOVERY REMAINING TO BE COMPLETED
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Respond to written discovery and conduct depositions.
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REASONS FOR REQUESTED EXTENSION
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A continued ENE is set for January 29, 2025. This extension is necessary to allow the parties
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to participate in the continued ENE and have ample time to complete all appropriate discovery, as
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well as preserve attorneys’ fees and costs towards good faith mediation.
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PROPOSED REVISED DISCOVERY PLAN
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1.
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The Parties’ current deadline for completing discovery is February 17, 2025. The Parties’
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Discovery Cut-Off Date:
request that the Court extend that deadline to Monday, May 19, 2025.
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2.
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The Parties’ current deadline to file dispositive is March 19, 2025. The Parties’ request that
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Dispositive Motions:
the Court extend that deadline to Tuesday, June 17, 2025.
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3.
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The Parties current deadline for filing the Joint Pretrial Order is April 18, 2025. The Parties’
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request that the Court extend that deadline to Thursday, July 17, 2025. In the event dispositive
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motions are filed, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days
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after the Court enters a ruling on the dispositive motions or otherwise by further order of the Court.
Pretrial Order:
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4.
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In accordance with Local Rule 26-3, a stipulation or motion for modification or extension
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of this discovery plan and scheduling order must be made no later than twenty (21) days before the
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expiration of the subject deadline.
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LITTLER MENDELSON, P.C.
3960 Howard Hughes Pkwy
Suite 300
Las Vegas, NV 89169.5937
702.862.8800
Extensions or Modifications of the Discovery Plan and Scheduling Order:
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4908-4882-2288
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