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Counter Wraps International, Inc. v. Diageo North America, Inc.

United States District Court, D. Nevada

December 14, 2017

COUNTER WRAPS INTERNATIONAL INC d/b/a DC MEDIA AND MARKETING, a Nevada corporation, Plaintiff,
v.
DIAGEO NORTH AMERICA INC., a Connecticut corporation; DIAGEO AMERICAS INC., a Delaware corporation; and DOES I through X; Defendants.

          HOWARD & HOWARD ATTORNEYS PLLC Robert Hernquist, Nevada Bar No. 10616 Jennifer Lloyd, Nevada Bar No. 9617 Attorneys for Defendants Diageo North America Inc. & Diageo Americas Inc.

          Paul B. Derby [pro hac vice] John J. O'Kane IV [pro hac vice] and RANDOLPH LAW FIRM Taylor Randolph, Nevada Bar No. 10194 Attorneys for Plaintiff Counter Wraps International Inc. d/b/a DC Media and Marketing

          STIPULATION AND PROPOSED MODIFIED SCHEDULING ORDER (SECOND REQUEST)

          C.W. HOFFMAN, JR. UNITED STATES MAGISTRATE JUDGE

         Pursuant to this Court's November 27, 2017 Order (ECF 30), and Local Rules 7-1 and 26-4, Plaintiff Counter Wraps International Inc. d/b/a DC Media and Marketing ("Plaintiff) and Defendants Diageo North America, Inc. and Diageo Americas Inc. (collectively "Defendants" and, together with Plaintiff, the "Parties") hereby respectfully submit this Stipulation and Proposed Modified Scheduling Order (Second Request):

         1. The operative Amended Scheduling Order entered by this Court on May 30, 2017 (ECF 21) contains the following deadlines:

a. Last date to complete discovery: November 9, 2017.
b. Last date to amend pleadings and add parties: Closed.
c. Last date to file interim status report: Closed.
d. Last date to disclose experts pursuant to Fed.R.Civ.P. 26(a)(2): September 12, 2017.
e. Last date to disclose rebuttal experts: October 12, 2017.
f. Last date to file dispositive motions: January 11, 2018.
g. Last date to file joint pretrial order: February 11, 2018. In the event that dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until thirty (30) days after the decision on the dispositive motions or until further order of the court.

         2. The parties have met and conferred, and stipulate, to the following proposed deadlines, subject to the ...


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