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

United States District Court, D. Nevada

June 28, 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, Defendants.

          GREGG A. HUBLEY, ESQ. Nevada Bar No. 7386 7030 Smoke Ranch Rd., Ste. B Las Vegas, NV 89128 -and- MICKEL MONTALBAN ARIAS, ESQ. (pro hac vice admitted) CA Bar No. 115385 6701 Center Drive West, 14th Floor Los Angeles, CA 90045 Attorneys for Plaintiff

          ELAYNA J. YOUCHAH, ESQ. Nevada Bar No. 5837 3800 Howard Hughes Pkwy., Ste. 600 Las Vegas, NV 89169 Attorneys for Defendant

          STIPULATION AND ORDER TO STAY DISCOVERY ANDEXTEND DISCOVERY DEADLINES (SECOND REQUEST)

         Plaintiff, JOHN DOE, and Defendant, RANALLI, ZANIEL, FOWLER & MORAN, LLC, (Collectively “the parties”), by and through their undersigned and respective counsel, 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. On May 15, 2018, this Court entered an Order granting the parties' Stipulation and Order to Extend Close of Discovery and Dispositive Motion Deadlines (First Request) [Doc. 27].
3. The parties are working together in good faith in an attempt to resolve all of the issues in this matter, and are in the process of scheduling private mediation with the Hon. Philip M. Pro (Ret.)
to take place before the end of August, 2018, if the parties are unable to resolve all issues beforehand without attending private mediation.
4. The parties stipulate and agree to stay discovery for sixty (60) days, for the purpose of allowing them to complete mediation. If the parties are unable to successfully resolve all issues before or after private mediation, the proposed plan below provides the parties with sufficient time to complete all discovery.
5. The parties further stipulate and agree to extend the dispositive motion and pre-trial order deadlines for an additional one hundred twenty (120) day period.
6. The parties further stipulate and agree that, during the sixty day stay of discovery, the Defendant is relieved of its obligation to serve responses to pending written discovery. Plaintiff has responded to all outstanding written discovery, and has undergone a deposition, and during the sixty day requested stay the Defendant will not serve any additional written discovery on Plaintiff.
7. The parties have vacated and/or rescheduled all noticed depositions. Neither party will issue a subpoena for deposition of a witness during the sixty day stay, and Plaintiff will not notice the deposition of any of Defendant's principals or employees during the sixty day stay.
8. The parties further stipulate and agree that if the parties are unable to reach an agreement during the sixty day stay, the Defendant's responses to the written discovery from Plaintiff will be due twenty (20) calendar days after the sixty day stay ends.
9. The parties further stipulate and agree that if the parties are unable to reach an agreement during the sixty day stay, the employees and principals of Defendant whose depositions have been noticed will work toward ensuring they are available for deposition within the sixty day period following the stay, and that their depositions will be completed, to the best of the parties abilities to do so, on or before September 14, 2018.

         STATEMENT OF DISCOVERY THAT ...


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