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McCart-Pollak v. Etkin

United States District Court, D. Nevada

December 27, 2017

SHANA LEE MCCART-POLLAK, Plaintiff,
v.
EDWARD ETKIN, an individual; LAW OFFICES OF EDWARD ETKIN, ESQ. PC a New York business entity; DOES I Through X; ROE BUSINESS ENTITIES I through X, inclusive, Defendants.

          LAXALT & NOMURA., DANIEL T. HAYWARD, Attorneys for Defendants Edward Etkin, and Law Offices of Edward Etkin, Esq. PC

          SHANA McCART-POLLAK, Plaintiff in Pro Per

          STIPULATED AMENDED SCHEDULING ORDER SUBMITTED IN COMPLIANCE WITH AMENDED MINUTE ORDER DATED 12/8/2017 (ECF NO. 64)

         Plaintiff Shana Lee McCart-Pollak, in pro per, and Defendants Edward Etkin and the Law Offices of Edward Etkin, Esq. PC, by and through their undersigned counsel, hereby submit the following proposed Amended Scheduling Order pursuant to Fed.R.Civ.P. 26(f)(3) and LRII26-1, and as directed by the Court's Amended Minute Order dated December 8, 2017 (ECF No. 64).

         Proposed Amended Scheduling Order

         1. Discovery cut-off date [LR II 26-l(b)(l)]:

         Proceedings in this matter are stayed by the Court's Minute Order dated December 8, 2017 (ECF No. 64). Discovery is closed, with the following exceptions:

         a. Plaintiff shall produce the text messages, voicemails, and emails identified by her pursuant to FRCP 26 and which are responsive to Defendants' requests for production on or before February 1, 2018. This may be done in cooperation with Holo, an IT vendor retained and paid for by Defendants. Plaintiff may produce the emails without the use of Holo's services if she is able.

         b. Plaintiff shall produce the complete contents of the United States Patent and Trademark Office patent application file wrappers / file histories for the '099 and '458 applications on or before February 1, 2018.

         c. Defendant Edward Etkin shall supplement his response to Interrogatory No. 4 (dates of hospital admissions). He has already done so.

         d. Defendants shall produce legible copies of those certain Verizon telephone records which Plaintiff asserted were illegible during the December 8, 2017 motion hearing. Defendants shall also identify their telephone service providers from January 1, 2012 through October 5, 2012. He has already done so.

         e. Plaintiff may serve a subpoena duces tecum on Defendants' telephone providers identified in response to paragraph 1(d).

         f. Plaintiff shall serve Defendants with any and all orders issued by the USPTO concerning the USPTO proceedings related to this matter as set forth in paragraph 3, below.

         2. Amending pleadings and adding parties [LR II 26-l(b)(2)]: Closed.

         3. Notice of further USPTO decisions / status report: Plaintiff shall promptly inform Defendants of the status of future USPTO decisions concerning the USPTO proceedings related to this matter by serving Defendants with ...


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