United States District Court, D. Nevada
KAEMPFER CROWELL, Joni A. Jamison Robert McCoy, BARNES &
THORNBURG LLP, Jonathan P. Froemel, Michael A. Carrillo,
Jonathan P. Froemel, Genevieve E. Charlton One North Wacker
Drive, Attorneys for Plaintiff.
FISHERBROYLES, LLP, Rob Phillips' FisherBroyles, LLP,
Attorney for Defendant
STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY
DEADLINES (FIRST REQUEST)
parties stipulate to extend the currently scheduled expert
discovery deadlines by 60 days. This is the first requested
extension of these deadlines. In support of this stipulation,
the parties state as follows:
Fed.R.Civ.P. 26(a)(1) Initial Disclosures:
parties served their initial disclosures on March 14, 2017.
served defendant with interrogatories, requests for
production of documents, and requests for admission on
December 9, 2016. Defendant responded to these written
discovery requests on January 20, 2017 and has agreed to
supplement these responses by May 22, 2017.
served plaintiff with interrogatories, requests for
production of documents, and requests for admission on April
21, 2017. Defendant has granted plaintiff an extension to
respond or object to these written discovery requests by June
has noticed the deposition of the following witnesses for the
following dates, though the parties are still negotiating the
potential rescheduling of some of these depositions:
June 12, 2017, 9:00 a.m.
June 16, 2017, 9:00 a.m.
The Agency, Inc. (30(b)(6))
June 19, 2017, time to be determined
June 20, 2017, time to be determined
June 21, 2017, time to be determined
REMAINING DISCOVERY TO BE COMPLETED
still owes plaintiff supplemental discovery responses, as
noted above. Plaintiff also still has outstanding discovery
responses that are due on June 20, 2017. In addition,
plaintiff plans to take the depositions noted above in June
2017. The parties may depose ...