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

United States District Court, D. Nevada

June 6, 2017

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

          GREGORY D. LATHAM, ESQ., STEPHEN KEPPER, ESQ. INTELLECTUAL PROPERTY CONSULTING, LLC AND JAMES E. WHITMIRE, ESQ. SANTORO WHITMIRE Attorneys for Plaintiff

          MARTIN I. MELENDREZ, ESQ. CHRISTOPHER A. ECCLES, ESQ. HAWKINS MELENDREZ, P.C. Attorneys for Two M., Inc. d/b/a Babe's Cabaret

          STIPULATION AND ORDER TO RESCHEDULE DEPOSITIONS

         Defendants, Two M, Inc. and Omar Aldabbagh, and plaintiff, Baskim Holdings, Inc. (the “Parties”), respectfully request that the Court extend the time for the Parties to take depositions previously ordered to be completed by June 12, 2017 (ECF 50). In support of this request, the Parties state:

         1. The Parties previously stipulated to, and the Court ordered (ECF 50), the following depositions take place in the following manner:

a. Defendants will make the following witnesses available for deposition at plaintiff s counsel's office over a three-day period of June 7, 8, and 9, 2017: Hilary Rush, Sara Bebee, Sarah Ruttenberg, Kelly Jones, Larry Wexler and Omar Aldabbagh.
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.
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. (the “Prior Depositions”).

         2. On May 18, 2017, the Court held a hearing on Defendants' Emergency Motion to Extend Time and Alter Discovery Deadlines (ECF 45); the Court ordered a forty-five (45) day extension of the following pre-trial deadlines: (1) discovery deadline extended until July 27, 2017; (2) the dispositive motion deadline extended to August 28, 2017; and (3) the joint pre-trial deadline extended until September 28, 2017 (ECF 53).

         3. In light of the depositions necessary to complete discovery prior to trial, and given the additional time allowed to finish discovery, the Parties believe it is in their best interest to attempt to resolve this matter prior to incurring the expenses associated with taking the previously scheduled Prior Depositions. Indeed, the parties have agreed to participate in a joint settlement conference with the magistrate judge in the coming months.

         4. Accordingly, the Parties request that the Court order the remaining Prior Depositions below be reset and taken based on the following agreed-upon schedule:

         a. Defendants will make the following witnesses available for deposition at plaintiff s counsel's office:

Hilary Rush

July 12, 2017 at 9:00 a.m. (PST)

Sarah Ruttenberg

July 12, 2017 at 1:00 p.m. (PST)

Sara Bebee

July 12, 2017 at 3:00 p.m. (PST)

Kelly Jones

July 13, 2017 at 3:00 p.m. (PST)

Larry Wexler

July 14, 2017 at 1:00 p.m. (PST)

Omar Aldabbagh[1]

July 14, 2017 at 9:00 a.m. (PST)

         b. Plaintiff will make the following witnesses available for deposition at defense counsel's ...


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