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Baskim Holdings, Inc. v. Two M, Inc.

United States District Court, D. Nevada

May 15, 2017

BASKIM HOLDINGS, INC., a Louisiana corporation, Plaintiff
v.
TWO M, INC. d/b/a BABE'S CABARET Defendant

          GREGORY D. LATHAM, ESQ. (admitted pro hac vice) Louisiana Bar No. 25955 STEPHEN KEPPER, ESQ. (admitted pro hac vice) Louisiana Bar No. 34618 INTELLECTUAL PROPERTY CONSULTING, LLC AND JAMES E. WHITMIRE, ESQ. Attorneys for Plaintiff

          MARTIN I. MELENDREZ, ESQ. Nevada Bar No. 7818 CHRISTOPHER A. ECCLES, ESQ. Nevada Bar No. 9798 HAWKINS MELENDREZ, P.C. Attorneys for Two M., Inc. d/b/a Babe's Cabaret

          STIPULATION AND ORDER FOR LIMITED EXTENSION OF DISCOVERY DEADLINE TO COMPLETE DEPOSITIONS

         Defendants, Two M, Inc. and Omar Aldabbagh, and plaintiff, Baskim Holdings, Inc., respectfully request that the Court extend the deadline for completion of depositions to June 12, 2017. In support of this request, the parties state:

         1. The current discovery deadline is May 22, 2017. (ECF 16, 25)

         2. Plaintiff has previously noticed the depositions of certain witnesses under defendants' control, namely, Hilary Rush, Sara Bebee, Sarah Ruttenberg, Kelly Jones, Larry Wexler and Omar Aldabbagh. Plaintiff has also served deposition subpoenas on three witnesses not under defendants' control, namely, Peter Feinstein, Danny Romine and Ken Bowman. All of these depositions were scheduled to take place over the three day period of May 17, 18 and 19, 2017.

         3. On April 24, 2017, attorneys Martin I. Melendrez and Christopher A. Eccles, were substituted as new counsel for defendants. (ECF 43). Defendants' new counsel are not available to participate in the depositions currently scheduled for May 17, 18 and 19, 2017. New defense counsel also require additional time to prepare for the depositions.

         4. Additionally, defendants desire to take the deposition of plaintiff's damages expert, Dr. Michael Einhorn. Defendants also desire to subpoena for deposition a non-party, namely, the landlord of plaintiff's New Orleans, Louisiana licensee.

         5. In light of defense counsel's very recent appearance in this case, the parties seek a limited extension of the discovery deadline to allow the above-described depositions to occur on or before June 12, 2017. More specifically, the parties have agreed on the following schedule:

a. Defendants will make the following witnesses available for deposition at plaintiff's counsel's office over the three day period of June 7, 8 and 9, 2017: Hilary Rush, Sara Bebee, Sarah Ruttenberg, Kelly Jones, Larry Wexler and Omar Aldabbagh.[1]
b. Plaintiff will reschedule the depositions of Peter Feinstein, Danny Romine and Ken Bowman, during the three day period of June 7, 8 and 9, 2017. If any of these three witnesses are unavailable during that time period, the parties will work together in good faith to schedule the deposition on or before June 12, 2017.
c. Plaintiff will make Dr. Michael Einhorn available for deposition at defense counsel's office on June 12, 2017.
d. Defendant may issue a deposition subpoena to plaintiffs New Orleans, Louisiana licensee s landlord, scheduling the deposition on or before June 12, 2017.

         6. Extending the time allowed to complete the above-described depositions will not impact the trial schedule in this case. On the other hand, defendants would be greatly prejudiced if the currently scheduled depositions were to occur on dates when counsel is not available; defendants would also be prejudiced by the inability to depose plaintiffs damages expert.

         7. On May 10, 2017, defendants filed an emergency motion seeking a 180-day extension of the deadlines for discovery, dispositive motions and filing of the joint pre-trial order. (ECF 45). Plaintiff opposes the extensions sought by defendants. This stipulation is not ...


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