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Barnes v. Bocci Engineering, LLC

United States District Court, D. Nevada

December 1, 2017

AJULENA BARNES, Plaintiff,
v.
BOCCI ENGINEERING, LLC, a Limited Liability Company; EMPLOYERS ONE SOURCE GROUP, INC., a foreign corporation; and DOES 1-50, inclusive, Defendants.

          Law Office of Mary F. Chapman, Ltd. Mary F. Chapman, Esq.

          Daniel R. Watkins, Esq. Theresa M. Santos, Esq. WATKINS & LETOFSKY, LLP

          FIRST JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY AND LIFT STAY

         Defendants Bocci Engineering, LLC and Employers One Source Group, Inc. by and through their new counsel Law Office of Mary F. Chapman, Ltd. and Plaintiff Ajulena Barnes by and through her attorney of record Watkins & Letofsky, LLP hereby make their First Request for an Extension of Time for Discovery pursuant to LR 6-1 and LR 26-4, and also request the Court officially lift the Stay currently in place.

         The Parties hereby stipulate and request that this Court grant their request to an extension of the discovery deadlines in the above-captioned case for one hundred twenty (120) days.

         In support of this Stipulation and Request, the parties state as follows:

         1. Plaintiff's Complaint was filed on January 11, 2017. On April 17, 2017, Plaintiff filed certificates of service for both Defendants.

         2. Defendants filed a partial motion to dismiss on June 26, 2017. The Court granted the partial motion to dismiss on August 8, 2017. On August 22, 2017, Defendants filed their Answers.

         3. On August 8, 2017, the Parties filed their Joint Discovery Plan. The Court issued the scheduling order on August 11, 2017. A Joint Interim Status Report was filed on October 26, 2017.

         4. The Parties filed Joint Stipulations to Stay proceedings pending the completion of the ENE and these requests were granted by the Court. (See, Docket Numbers 9-12, 15-16, and 25-26). The ENE conference was held on October 30, 2017, a settlement was not reached. After completion of the ENE the stay was inadvertently not lift by the clerk of court.

         4. The parties have exchanged information as required by Fed.R.Civ.P. 26(a)(1)., and have also supplemented their Initial Disclosures.

         5. On November 9, 2017, Plaintiff served Request for Production of Documents and Interrogatories on both Defendants. These responses are not yet due, but Plaintiff has agreed to an extension of time for responses until January 11, 2018, based upon the appearance of new counsel.

         6. On November 28, 2017, Defendants filed a substitution of counsel.

         7. Based upon the Court approved Stays in this case the Parties have actually only had from November 1, 2017 until the scheduled cut off of December 26, 2017, a total of fifty-six (56) days which includes two holidays. This is an inadequate time to complete discovery especially given the change of legal counsel. Accordingly, the extension requested by the Parties would allow the Parties the regular 180 day discovery period.

         10. The following is a list of the current discovery deadlines and the ...


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