United States District Court, D. Nevada
Office of Mary F. Chapman, Ltd. Mary F. Chapman, Esq.
R. Watkins, Esq. Theresa M. Santos, Esq. WATKINS &
FIRST JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY
AND LIFT STAY
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.
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.
support of this Stipulation and Request, the parties state as
Plaintiff's Complaint was filed on January 11, 2017. On
April 17, 2017, Plaintiff filed certificates of service for
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
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.
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.
parties have exchanged information as required by
Fed.R.Civ.P. 26(a)(1)., and have also supplemented their
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.
November 28, 2017, Defendants filed a substitution of
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
following is a list of the current discovery deadlines and