King v. Amazon.com Services, LLC

Filing 30

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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1 2 3 4 5 6 7 8 9 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 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 11 12 CARRIEL KING, 13 14 15 16 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. 17 18 Pursuant to Local Rule IA 6-1 and Local Rule 26-3, Defendant AMAZON.COM 19 20 21 22 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 23 24 25 26 27 28 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. /// /// LITTLER MENDELSON, P.C. 3960 Howard Hughes Pkwy Suite 300 Las Vegas, NV 89169.5937 702.862.8800 4908-4882-2288 1 DISCOVERY COMPLETED 2 3 The parties have each exchanged their initial disclosures, propounded written discovery, and issued initial deposition notices. 4 DISCOVERY REMAINING TO BE COMPLETED 5 Respond to written discovery and conduct depositions. 6 REASONS FOR REQUESTED EXTENSION 7 A continued ENE is set for January 29, 2025. This extension is necessary to allow the parties 8 to participate in the continued ENE and have ample time to complete all appropriate discovery, as 9 well as preserve attorneys’ fees and costs towards good faith mediation. 10 PROPOSED REVISED DISCOVERY PLAN 11 1. 12 The Parties’ current deadline for completing discovery is February 17, 2025. The Parties’ 13 Discovery Cut-Off Date: request that the Court extend that deadline to Monday, May 19, 2025. 14 2. 15 The Parties’ current deadline to file dispositive is March 19, 2025. The Parties’ request that 16 Dispositive Motions: the Court extend that deadline to Tuesday, June 17, 2025. 17 3. 18 The Parties current deadline for filing the Joint Pretrial Order is April 18, 2025. The Parties’ 19 request that the Court extend that deadline to Thursday, July 17, 2025. In the event dispositive 20 motions are filed, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days 21 after the Court enters a ruling on the dispositive motions or otherwise by further order of the Court. Pretrial Order: 22 4. 23 In accordance with Local Rule 26-3, a stipulation or motion for modification or extension 24 of this discovery plan and scheduling order must be made no later than twenty (21) days before the 25 expiration of the subject deadline. 26 /// 27 /// 28 /// 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: 2 4908-4882-2288

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