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Resoso v. Clausing Industrial, Inc.

United States District Court, D. Nevada

November 16, 2017

CHARLIE RESOSO, Plaintiff.
v.
CLAUSING INDUSTRIAL, INC., ANILOX ROLL COMPANY WEST. INC d/b/a ARC INTERNATIONAL; ANILOX ROLL COMPANY, INC. d/b/a ARC INTERNATIONAL, inclusive, Defendants, CLAUSING INDUSTRIAL, INC. Cross-Claimant,
v.
ANILOX ROLL COMPANY, INC, Cross-Defendant. Current Dates Proposed New Dates

          BRENSKE & ANRREEVSKI WILLIAM R BRENSKE ESQ. Attorneys for .Plaintiff Charlie Resoso

          LITCHFIELD CAVO LLP, GRIFTTTH H, HAYES, ESQ. Attorneys for Defendant/Cross-Defendant Anilox Roll Company, Inc. d/h/a ARC International, Inc.

          YARON & ASSOCIATES GEORGE D. YARON, ESQ. KEITH E. PATTERSON, ESQ. Attorneys for Defendant/Cross-Claimant Clausing Industrial, Inc.

          STIPULATION AND PROPOSED ORDER TO AMEND DISCOVERY PLAN

         IT IS HEREBY STIPULATED by and between Plaintiff CHARLIE RESOSO ("PLAINTIFF"), by and through his counsel of record, WILLIAM R. BRENSKE, ESQ, of the law firm of BRENSKE & ANDREEVSKI; Defendant/Cross-Defendant ANILOX ROLL COMPANY, INC, d/b/a ARC INTERNATIONAL ("ARC EAST"), by and through its counsel of record, GRIFFITH IL HAYES, ESQ. and KE1VAN A. ROEBUCK, ESQ. of the law firm of LITCHFIELD CAVO LLP; and Defendant CLAUSING INDUSTRIAL, INC, ("CLAUSING"), by and through its counsel of record, GEORGE D. YARON, ESQ. and KEITH E. PATTERSON, ESQ. of the law firm of Y A RON & ASSOCIATIES, to extend discovery deadlines for good cause shown. This Stipulation and Proposed Order is submitted pursuant to and in compliance with LR IA 6-1 and LR 26-4, as follows:

         1. Statement Specifying the Discovery Completed

         On September 28, 2017, ARC EAST filed its Motion for Summary Judgment ("MSJ"), On September 29, 2017, ARC EAST'S Motion for Protective Order Regarding the FRCP 30(b)(6) Deposition of ARC EAST was heard by United States Magistrate Judge George W. Foley. ARC EAST'S Motion for Protective Order was granted, and as such, ARC EAST agreed to make its FRCP 30(b)(6) witnesses available at a time convenient for all parties. The Court also held in abeyance ARC EAST'S disclosure of expert witnesses pending a further ruling by the Court on ARC EAST'S MSJ. The Court further held that should the Court deny the MSJ, the parties will be given adequate time to designate/disclose expert witnesses, rebuttal witnesses and complete disclosure, as discussed in open court.

         2. A Specific Description of the Discovery that Remains to be Completed

         The FCRP 30(b)(6) depositions must be completed, ARC EASTs MSJ must be fully briefed, and the parties need to designate/disclose expert witnesses, rebuttal witnesses, and complete disclosure.

         3. Reasons Why Discovery Is Not Completed

         Because of a family medical emergency concerning one of ARC EAST'S FRCP 30(b)(6) deponents, ARC EAST needs to move the FRCP 30(b)(6) depositions to a later date.

         4. Proposed Schedule for Completing AH Remaining Discovery

         The parties request a brief extension as follows:

Current Dates
Proposed New Dates

FRCP 30(b)(6) depositions of ARC EAST

November 15, 2017 November 16, 2017

December 14, 2017 at 10:30 am

December 15, 2017 at 9:00 a.m,

Oppositions to ARC EAST'S MS J

December 18, 2017

January 19, 2018

ARC EAST'S Reply in Support of MSJ

January 10; 2018

February 2, 2018

ARC EAST'S Motion to Further Stay Disclosure of Expert Witnesses

January 17, 2018

February 9, 2018

         All other discovery cut-off dales stated in the parties' Discovery Plan and Scheduling Order filed October 17, 2017 ...


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