United States District Court, D. Nevada
Matthew I. Knepper, Esq. Miles N. Clark, Esq. Nevada Bar No.
H. Krieger, Esq. Nevada Bar No. 9086 HAINES & KRIEGER,
LLC Attorneys for Plaintiff
Michael R. Brooks, Esq. Nevada Bar No. 7287 KOLESAR &
Richard J. Reynolds, Esq. BURKE, WILLIAMS & SORENSEN, LLP
Counsel for Defendants Trinity Financial Services, LLC and
Trinity Recovery Services, LLC
STIPULATION FOR EXTENSION OF TIME (FIRST
to LR 6-1 and LR 26-4, Plaintiff and Defendants Trinity
Financial Services, LLC and Trinity Recovery Services, LLC
(collectively, “Defendants”), by and through
their respective counsel of record, hereby stipulate and
request that this Court extend the discovery deadline by
sixty (60) days. At this time, the parties are not seeking an
extension of any other STIPULATION FOR EXTENSION OF
TIME(FIRST REQUEST) - 1 discovery deadlines but reserve the
right to request in the future depending on adjudication of
Plaintiff's Motion for Leave to Amend, ECF Dkt. 8. In
support of this Stipulation and Request, the parties state as
DISCOVERY COMPLETED TO DATE
Plaintiff filed the instant complaint on June 26, 2017. ECF
August 4, 2017, Defendants filed their answers. ECF Dkt. 4,
September 15, 2018, Plaintiff served his Initial Disclosures.
September 18, 2017, Plaintiff moved for leave to amend his
complaint. ECF Dkt. 8.
September 28, 2017, the Court granted the parties'
stipulated protective order. ECF Dkt. 11.
October 10, 2017, the Court granted the parties'
stipulated discovery plan and scheduling order. ECF Dkt. 17.
October 13, 2017, Plaintiff propounded his First Set of
Requests for Production and Interrogatories on Defendants.
November 17, 2017, Defendants responded to Plaintiff's
First Set of Requests ...