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Dish Network Corp. v. Lohrengel

United States District Court, D. Nevada

December 1, 2017

DISH NETWORK CORPORATION, As Plan Administrator And On Behalf Of DISH NETWORK CORPORATION 401(K) PLAN, Plaintiff,
v.
ROY LOHRENGEL, and DEBORAH POMPA Defendants DEBRA JEAN POMPA, Cross-claim Plaintiff,
v.
ROY LOHRENGEL, Cross-claim Defendant.

          Andrew F. Dixon Nevada Bar No. 8422 Bowler Dixon & Twitchell LLP Attorneys for Defendant/ Cross-claim Plaintiff Debra Jean Pompa

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         Defendant/Cross-Claim Plaintiff/Cross-Claim Defendant DEBRA JEAN POMPA (“Pompa”); Defendant/Cross-Claim Plaintiff/Cross-Claim Defendant ROY LOHRENGEL (“Lohrengel”); and Plaintiff DISH NETWORK CORPORATION, As Plan Administrator And On Behalf Of DISH NETWORK CORPORATION 401(K) PLAN (“Plaintiff”), by and through their respective undersigned counsel of record, hereby stipulate and request that the Court extend certain discovery deadlines by approximately ninety (90) days. This is the first request by any party to extend any discovery deadlines in this matter. Pursuant to Local Rule 26-4, the parties state as follows:

         I. DISCOVERY COMPLETED TO DATE

         • The parties conducted the Fed.R.Civ.P. 26(f) conference.

         • Plaintiff and Pompa have served their initial disclosures of documents and lists of witnesses. Lohrengel has not served his initial disclosures but has agreed to do so by November 30, 2017.

         • Pompa has served the following written discovery on Lohrengel:

o Pompa's First Set of Interrogatories, served on November 17, 2017.
Responses are due December 20, 2017.
o Pompa's First Requests for Production of Documents, served on November 17, 2017. Responses are due December 20, 2017.

         • Pompa has served the following written discovery on Plaintiff:

o Pompa's First Set of Interrogatories, served on November 17, 2017.
Responses are due December 20, 2017.
o Pompa's First Requests for Production of Documents, served on November 17, 2017. Responses are due December 20, 2017.

         II. DISCOVERY ...


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