United States District Court, D. Nevada
W. FREEMAN, ESQ. Nevada Bar No. 003062 PRISCILLA L.
O'BRIANT, ESQ. Attorneys for Defendant
P. CLARK, ESQ. Nevada Bar No. 04236 LUKAS B. MCCOURT, ESQ
Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND TIME TO FILE
DISPOSITIVE MOTIONS (THIRD REQUEST)
to LR 6-1 and LR 26-4, the parties, by and through their
respective counsel of record, hereby stipulate and request
that this court extend the deadline for dispositive motions.
This is the third stipulation for extension of time to file
motions. In support of this Stipulation and Request, the
parties state as follows:
December 2, 2015, Plaintiff filed her Amended Complaint in
December 11, 2015, Plaintiff served the Amended Complaint on
the Nevada Department of Business and Industry, Division of
January 13, 2016, Defendant removed the matter to this Court.
January 13, 2016, Defendant Answered the Amended Complaint.
February 8, 2016, the parties conducted an initial 26(f)
February 10, 2016, the parties prepared and submitted a
Stipulated Discovery Plan and Scheduling Order (the
“Order”) for the Court's approval.
February 11, 2016, the Court entered the Stipulated Order.
February 22, 2016, Defendant served its Initial List of
Witnesses and Documents pursuant to FRCP 26.
March 1, 2016, Defendant propounded written discovery upon
March 2, 2016, Defendant served its Initial List of Witnesses