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Mott v. Trinity Financial Services, LLC

United States District Court, D. Nevada

May 29, 2018

RODNEY MOTT, Plaintiff,
v.
TRINITY FINANCIAL SERVICES, LLC; and TRINITY RECOVERY SERVICES, LLC, Defendants.

          Alan Ceran, Esq. BURKE, WILLIAMS & SORENSEN, LLP, Richard J. Reynolds, Esq. BURKE, WILLIAMS & SORENSEN, LLP, Michael R. Brooks, Esq. KOLESAR & LEATHAM, Counsel for Defendants.

          Matthew I. Knepper, Esq., Miles N. Clark, Esq., KNEPPER & CLARK LLC, David H. Krieger, Esq., HAINES & KRIEGER, LLC, Attorneys for Plaintiff.

          STIPULATION FOR EXTENSION OF TIME

         Pursuant 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 thirty (30) days. At this time, the parties are not seeking an extension of any other 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 follows:

         I. DISCOVERY COMPLETED TO DATE

         1. Plaintiff filed the instant complaint on June 26, 2017. ECF Dkt. 1.

         2. On August 4, 2017, Defendants filed their answers. ECF Dkt. 4, 5.

         3. On September 15, 2018, Plaintiff served his Initial Disclosures.

         4. On September 18, 2017, Plaintiff moved for leave to amend his complaint. ECF Dkt. 8.

         5. On September 28, 2017, the Court granted the parties' stipulated protective order. ECF Dkt. 11.

         6. On October 10, 2017, the Court granted the parties' stipulated discovery plan and scheduling order. ECF Dkt. 17.

         7. On October 13, 2017, Plaintiff propounded his First Set of Requests for Production and Interrogatories on Defendants.

         8. On November 17, 2017, Defendants responded to Plaintiff's First Set of Requests for Production and Interrogatories.

         9. On December 9, 2017, Plaintiff served his First Supplemental Disclosures.

         10. On December 12, 2017, the parties conducted a Rule 26-7 conference regarding Defendants' responses to Plaintiff's First Set of ...


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