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Doe v. Ranalli, Zaniel, Fowler & Moran, LLC

United States District Court, D. Nevada

May 15, 2018

JOHN DOE, individually, Plaintiff,
v.
RANALLI, ZANIEL, FOWLER & MORAN, LLC, a Nevada Limited Liability Company, DOES I-X, and ROE CORPORATIONS I-X, inclusive, Defendant.

          JACKSON LEWIS P.C. ELAYNA J. YOUCHAH, Bar #5837 DIONE C. WRENN, Bar #13285 Attorneys for Defendant.

          ARIAS SANGUINETTI WANG & TORRIJOS GREGG A. HUBLEY, Bar #7386 Attorney for Plaintiff John Doe.

          STIPULATION AND ORDER TO EXTEND CLOSE OF DISCOVERY AND DISPOSITIVE MOTION DEADLINES

         The parties, by and through their respective counsel of record, hereby stipulate and agree as follows:

1. On January 23, 2018, this Court entered an Order granting the Stipulated Discovery Plan and Scheduling Order submitted by the parties.
2. This is the first request by the parties to amend the Court's January 23, 2018 Scheduling Order.
3. The parties stipulate and agree to extend the close of discovery deadline for thirty-five (35) days for the sole purpose of conducting party and percipient witness depositions, some of which are out-of-state, that are necessary to fully evaluate the claims and defenses presented.
4. The parties further stipulate and agree that the dispositive motion and pre-trial order deadlines shall also be extended pursuant to LR 26-1.
5. The parties further stipulate and agree that the period to propound written discovery requests shall not be extended by this Stipulation and Order.

         STATEMENT OF DISCOVERY THAT HAS BEEN COMPLETED

         1. Plaintiff served the following disclosures:

a. Initial Disclosures on January 23, 2018;
b. First Supplemental Disclosures on February 16, 2018; c. Second Supplemental Disclosures on March 2, 2018.

         2. Defendant served the ...


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