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Resoso v. Clausing Industrial, Inc.

United States District Court, D. Nevada

January 5, 2018

CHARLIE RESOSO, Plaintiff,
v.
CLAUSING INDUSTRIAL, INC.. ANILOX ROLL COMPANY WEST, INC. d/b/a ARC INTERNATIONAL ANILOX ROLL COMPANY. INC. d/b/a ARC INTERNATIONAL, inclusive, Defendants. CLAUSING INDUSTRIAL, INC. Cross-Claimant,
v.
ANILOX ROLL COMPANY, INC. Cross-Defendant.

          GRIFFITH H. HAYES, ESQ. KEIVAN A. ROEBUCK. ESQ. Attorneys for Defendant/Cross-Defendant Anilox Roll Company, Inc. d/b/a ARC International, Inc.

          BRENSKE & ANDREEVSKI WILLIAM R. BRENSKE, ESQ. Attorneys for Plaintiff Charlie Resoso

          YARON & ASSOCIATES GEORGE D. YARON, ESQ. KEITH E. PATTERSON, ESQ. Attorneys for Defendant/Cross-Claimant Clausing Industrial, Inc

          STIPULATION AND PROPOSED ORDER TO AMEND DISCOVERY PLAN (SECOND REQUEST)

         STIPULATION AND PROPOSED ORDER TO AMEND DISCOVERY PLAN

         IT IS HEREBY STIPULATED by and between Plaintiff CHARLIE RESOSO ("PLAINTIFF"), by and through his counsel of record, WILLIAM R. BRENSKE, ESQ. of the law firm of BRENSKE & ANDREEVSKI; Defendant/Cross-Defendant ANILOX ROLL COMPANY, INC. d/b/a ARC INTERNATIONAL ("ARC EAST"), by and through its counsel of record, GRIFFITH H. HAYES, ESQ. and KEIVAN A. ROEBUCK, ESQ. of the law firm of LITCHFIELD CAVO LLP; and Defendant CLAUSING INDUSTRIAL, INC. ("CLAUSING"), by and through its counsel of record, GEORGE D. YARON, ESQ. and KEITH E. PATTERSON, ESQ. of the law firm of YARON & ASSOCIATIES, to extend discovery deadlines for good cause shown. This Stipulation and Proposed Order is submitted pursuant to and in compliance with LR IA 6-1 and LR 26-4, as follows:

         1. Statement Specifying the Discovery Completed

         On September 28, 2017, ARC EAST filed its Motion for Summary Judgment ("MSJ"). On September 29, 2017, ARC EAST'S Motion for Protective Order Regarding the FRCP 30(b)(6) Deposition of ARC EAST was heard by United States Magistrate Judge George W. Foley. ARC EAST'S Motion for Protective Order was granted, and as such, ARC EAST agreed to make its FRCP 30(b)(6) witnesses available at a time convenient for all parties. The Court also held in abeyance ARC EAST'S disclosure of expert witnesses pending a further ruling by the Court on ARC EAST'S MSJ. The Court further held that should the Court deny the MSJ, the parties will be given adequate time to designate/disclose expert witnesses, rebuttal witnesses and complete disclosure, as discussed in open court.

         On December 14, 2017 and December 15, 2017, the FRCP 30(b)(6) deposition of ARC EAST was held. During that time, the parties learned that there are additional persons most knowledgeable of ARC EAST that will need to be deposed in order to complete the FRCP 30(b)(6) deposition of ARC EAST.

         2. A Specific Description of the Discovery that Remains to be Completed

         The FCRP 30(b)(6) deposition must be completed, ARC EAST'S MSJ must be fully briefed, and the parties need to designate/disclose expert witnesses, rebuttal witnesses, and complete disclosure.

         3. Reasons Why Discovery Is Not Completed

         Because of a family medical emergency concerning one of ARC EAST'S FRCP 30(b)(6) deponents, ARC EAST needed to move the FRCP 30(b)(6) deposition to a later date, which was the basis of the parties' Stipulation and Order to Amend Discovery Plan (First Request). Now that the FRCP 30(b)(6) deposition has begun, it was discovered that additional persons most knowledgeable of ARC EAST need to be deposed in order to complete the FRCP 30(b)(6) deposition.

         4. Proposed Schedule for Completing All ...


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