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Marks v. David Saxe Productions, LLC

United States District Court, D. Nevada

December 28, 2017

ALEXANDER MARKS, an individual, Plaintiff,
v.
DAVID SAXE PRODUCTIONS, LLC; SAXE MANAGEMENT, LLC; DAVID SAXE, an individual; EMPLOYEES / AGENTS DOES 1-10; and ROE CORPORATRIONS 11-20, inclusive, Defendants.

          JEFFREY GRONICH, ATTORNEY AT LAW Jeffrey Gronich, Esq., JACKSON LEWIS P.C. Kirsten A. Milton, Attorneys for Defendants David Saxe Productions, LLC, Saxe Management, LLC and David Saxe.

          STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (FIRST REQUEST)

          C.W. Hoffman, Jr., Judge.

         Pursuant to LR 26-4, all parties hereby stipulate to extend the discovery plan and scheduling order deadlines in this action pursuant to LR 26-4. This is the first request for an extension to the discovery plan and scheduling order in this matter.

         I. INTRODUCTION

         On September 21, 2017, this Court granted the parties' discovery plan and scheduling order. ECF No. 12. Unfortunately, Defendants' counsel has experienced a substantial unforeseen workload which is based on unexpected court filings. In light of these events, the parties request an additional 60-day extension to the current discovery deadlines.

         II. DISCOVERY COMPLETED TO DATE:

         Plaintiff:

Initial Disclosures to Defendants October 3, 2017
First Set of Requests for Production of Documents to Defendants December 1, 2017
First Set of Interrogatories to Defendants December 1, 2017

         Defendants:

Initial Disclosures to Plaintiff October 3, 2017

         III. DISCOVERY YET TO BE COMPLETED:

         Plaintiff will notice depositions of employees of Defendants who Plaintiff believes are likely to have discoverable information that Plaintiff may use to support his ...


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