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Garis v. Gypsum Resources Materials, LLC

United States District Court, D. Nevada

June 9, 2017

KARRI GARIS, Plaintiff,
v.
GYPSUM RESOURCES MATERIALS, LLC, a Nevada Limited Partnership; TRUCKEE SPRINGS HOLDINGS, INC., a Nevada Corporation; JAMES M. RHODES, an individual; DOES I-X; ROE BUSINESS ENTITIES I-X, Defendants.

          JAMES P. KEMP, ESQ. KEMP & KEMP Attorneys for Plaintiff KARRI GARIS

          ROGER L. GRANDGENETT II, ESQ.KATHRYN B. BLAKEY, ESQ., LITTLER MENDELSON, P.C. GYPSUM RESOURCES MATERIALS, LLC, TRUCKEE SPRINGS HOLDINGS, INC., AND JAMES M. RHODES

          [PROPOSED] STIPULATION AND ORDER TO EXTEND DISCOVERY [SECOND REQUEST]

         Plaintiff, KARRI GARIS and Defendants, GYPSUM RESOURCES MATERIALS, LLC, TRUCKEE SPRINGS HOLDINGS, INC., and JAMES M. RHODES, (collectively “Defendants”), by and through their respective counsel of record, do hereby stipulate and agree to amend the current scheduling order and discovery plan by extending the discovery cut-off date of June 30, 2017 for an additional 90 days until September 28, 2017, with the following discovery dates also being extended:

         1. Dispositive Motions:

         The parties shall file dispositive motions not more than (30) days after the discovery cut-off date and, therefore, not later than Monday, October 30, 2017.

         2. Pretrial Order:

         If no dispositive motions are filed, and unless otherwise ordered by this Court, the Joint Pretrial Order shall be filed not more than thirty (30) days after the date set for filing dispositive motions and, therefore, not later than Wednesday, November 29, 2017.

         3. Fed.R.Civ.P. 26(a)(3) Disclosures:

         If no dispositive motions are filed, and unless otherwise ordered by this Court, the parties shall file the disclosures required by Fed.R.Civ.P. 26(a)(3) and any objections thereto with the Pretrial Order pursuant to LR 26-1(e)(6) in the Joint Pretrial Order, not more than thirty (30) days after the date set for filing dispositive motions and, therefore, not later than Wednesday, November 29, 2017.

         4. Extensions or Modifications of the Discovery Plan and Scheduling Order:

         In accordance with Local Rule 26-4, a stipulation or motion for modification or extension of any deadline set forth herein must be made no later than twenty-one (21) days before the expiration of the subject deadline.

         DISCOVERY COMPLETED TO DATE

         To date, the parties have completed ...


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