United States District Court, D. Nevada
& NOMURA., DANIEL T. HAYWARD, Attorneys for Defendants
Edward Etkin, and Law Offices of Edward Etkin, Esq. PC
McCART-POLLAK, Plaintiff in Pro Per
STIPULATED AMENDED SCHEDULING ORDER SUBMITTED IN
COMPLIANCE WITH AMENDED MINUTE ORDER DATED 12/8/2017 (ECF NO.
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
Amended Scheduling Order
Discovery cut-off date [LR II 26-l(b)(l)]:
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:
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.
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.
Defendant Edward Etkin shall supplement his response to
Interrogatory No. 4 (dates of hospital admissions). He has
already done so.
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.
Plaintiff may serve a subpoena duces tecum on Defendants'
telephone providers identified in response to paragraph 1(d).
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.
Amending pleadings and adding parties [LR II 26-l(b)(2)]:
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 ...