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UMRO Realty Corp. v. Agency, Inc.

United States District Court, D. Nevada

May 19, 2017

UMRO REALTY CORP d/b/a THE AGENCY, Plaintiff,
v.
THE AGENCY, INC., Defendant.

          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)

         The 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:

         I. DISCOVERY COMPLETED

         A. Fed.R.Civ.P. 26(a)(1) Initial Disclosures:

         Both parties served their initial disclosures on March 14, 2017.

         B. Written Discovery:

         Plaintiff 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.

         Defendant 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 20, 2017.

         C. Depositions:

         Plaintiff 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:

Kathryn Holbert

June 12, 2017, 9:00 a.m.

Marie Wdzieczkewski

June 16, 2017, 9:00 a.m.

The Agency, Inc. (30(b)(6))

June 19, 2017, time to be determined

Randolph Reyes

June 20, 2017, time to be determined

Lenny Gervasio

June 21, 2017, time to be determined

         II. REMAINING DISCOVERY TO BE COMPLETED

         Defendant 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 ...


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