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YWS Architects, LLC v. Alon Las Vegas Resort, LLC

United States District Court, D. Nevada

May 23, 2018

YWS Architects, LLC dba YWS Design & Architecture, a Nevada limited liability company, Plaintiff,
v.
Alon Las Vegas Resort, LLC, a Delaware limited liability company; Alon Las Vegas Landco, LLC, a Delaware limited liability company; TISHMAR, LLC, a Nevada limited liability company, Defendants. Alon Las Vegas Resort, LLC, a Delaware limited liability company; Alon Leisure Management, LLC, a Delaware limited liability company, Counter-claimants,
v.
YWS Architects, LLC dba YWS Design & Architecture, a Nevada limited liability company; Tom Wucherer, an individual; DOES 1 through 10; ROE CORPORATIONS 11-20, Counter-defendants.

          GREENBERG TRAURIG, LLP Shauna L. Norton, Mark G. Tratos, Esq. Attorneys for Plaintiff YWS Architects, LLC dba YWS Design & Architecture

          MEAD LAW GROUP Sarah A. Mead, Leon F. Mead II, Esq., Patrick G. Byrne, Esq., Michael Paretti, Esq. Snell & Wilmer L.L.P. Attorneys for Counterclaimants Alon Las Vegas Resort, LLC and Alon Leisure Management, LLC

          STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DATES AND DEADLINES

         Plaintiff YWS Architects, LLC dba YWS Design & Architecture (“Plaintiff” or “YWS”) and Tom Wucherer (“Wucherer”), by and through their counsel of record, the law firm of Greenberg Traurig, LLP and Rourke Law Firm, and Counterclaimants Alon Las Vegas Resort, LLC and Alon Leisure Management, LLC (collectively “Alon Group”), by and through their counsel, Mead Law Group and Snell & Wilmer LLP (collectively the “Parties”), for good cause shown, pursuant to Local Rules 26-4 and 6-1, hereby submit the following Stipulation.

         I. DISCOVERY COMPLETED TO DATE

         As required by FRCP 26 and Local Rule 26-1(d), counsel for the Parties held a telephone conference on August 4, 2017 to discuss initial discovery disclosures and to develop a discovery plan. Initial and Supplemental disclosures were subsequently served as required by FRCP 26(a)(1). YWS has produced six supplemental disclosures since that time. Alon has produced three supplemental disclosures since that time.

         On January 24, 2018, the Parties submitted their first request to extend the discovery plan and scheduling order dates and deadlines [Doc. 71]. The Court granted this request the same day. [Doc. 73].

         The Parties have exchanged the following written discovery to Dated:

1. On September 13, 2017, Alon propounded its First Set of Requests for Production of Documents, its First Set of Requests for Admission, and its First Set of Interrogatories upon YWS. On October 27, 2018, YWS served its responses thereto.
2. On September 15, 2017, YWS propounded its First Set of Requests for Production of Documents, its First Set of Requests for Admission, and its First Set of Interrogatories upon Alon. On November 6, 2017, Alon served its responses thereto.
3. After a meet and confer and a letter requesting supplemental responses written by Alon, YWS produced its supplemental responses to Alon's First Set of Admissions and First Set of Interrogatories on March 5, 2018.
4. In October, YWS issued several subpoenas duces tecum to various third parties.
5. On January 10, 2018, the deposition of the Person Most Knowledgeable for Penta Building Group was taken by the Parties.
6. On April 10, 2018, Alon noticed the deposition of YWS' Person(s) Most Knowledgeable for May 8, 2018, explaining that the date was flexible if it did not work for YWS or its counsel.
7. In April and May of 2018, the Parties discussed dates for depositions of YWS' Person(s) Most Knowledgeable as well as various witnesses listed on Alon's disclosure statements: Andre ...

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