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Doe v. Ranalli, Zaniel, Fowler & Moran, LLC
United States District Court, D. Nevada
May 15, 2018
JOHN DOE, individually, Plaintiff,
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.
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
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
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.
OF DISCOVERY THAT HAS BEEN COMPLETED
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.
Defendant served the ...