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Rock v. Ninyo & Moore, Geotechnical Consultants

United States District Court, D. Nevada

February 6, 2018

LOUIS ROCK and DEBBY ROCK, Individually and as Husband and Wife, Plaintiffs,
v.
NINYO & MOORE, GEOTECHNICAL CONSULTANTS dba NINYO & MOORE GEOTECHNICAL & ENVIRONMENTAL SCIENCES CONSULTANTS, a Foreign Corporation; ROADSAFE TRAFFIC SYSTEMS, INC., a Foreign Corporation; DOE INDIVIDUALS 1 through 100; and ROE CORPORATIONS 1 through 100, inclusive, Defendants.

          EGLET PRINCE, ROBERT T. EGLET, ESQ, TRACY A. EGLET, ESQ, JOSEPH J. TROIANO, ESQ, Attorneys for Plaintiff

          HALL JAFFE & CLAYTON, LLP., MICHAEL R. HALL, ESQ, Attorney for Defendants

          CISNEROS & MARIAS, JASON C. FOULGER, ESQ., Attorney for Defendants

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)

         IT IS HEREBY STIPULATED by and between Plaintiffs LOUIS AND DEBBY ROCK, by and through their counsel of record, JOSEPH TROIANO, ESQ., of EGLET PRINCE, Defendant ROADSAFE TRAFFIC SYSTEMS, INC. by and through their counsel of record, JASON C. FOULGER, ESQ., of CISNEROS & MARIAS, Defendant NINYO & MOORE, GEOTECHNICAL DBA CONSULTANTS DBA NINYO & MOORE GEOTECHNICAL & ENVIROMENTAL SCIENCES CONSULTANTS by and through their counsel of record, MICHAEL R. HALL, ESQ., of HALL JAFFE & CLAYTON, LLP., that discovery in this matter shall be extended for the limited purpose of completing the discovery described herein. Pursuant to Local Rules (“LR”) 6-1, 6-2, 7-1, and 26-4, the parties offer the following in support of their stipulation to extend discovery:

         I. DISCOVERY COMPLETED TO DATE

         Plaintiffs served Defendants with the following discovery to Dated:

1. Plaintiffs' Initial NRCP 16.1 disclosures and Four (4) Supplements thereto;
2. Plaintiffs' Responses to Defendant's Requests for Production, Requests for Admissions and Interrogatories; and
3. Plaintiffs' Requests for Production, Requests for Admissions and Interrogatories to Defendants;
4. Plaintiffs' Expert Disclosure and Supplemental NRCP 16.1 (a)(3) Pre-Trial Disclosures and Two (2) Supplements thereto.

         Defendant Roadsafe Traffic Systems, Inc., served Plaintiffs with the following discovery to Dated:

1. Defendant's Initial NRCP 16.1 disclosure;
2. Defendant's Requests for Production of Documents, Interrogatories and Requests for ...

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