United States District Court, D. Nevada
Ceran, Esq. BURKE, WILLIAMS & SORENSEN, LLP, Richard J.
Reynolds, Esq. BURKE, WILLIAMS & SORENSEN, LLP, Michael
R. Brooks, Esq. KOLESAR & LEATHAM, Counsel for
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
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
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 for Production and Interrogatories.
December 9, 2017, Plaintiff served his First Supplemental
December 12, 2017, the parties conducted a Rule 26-7
conference regarding Defendants' responses to
Plaintiff's First Set of ...