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Focalpoint International Inc. v. Dom Rubino Consulting Services Inc.

United States District Court, D. Nevada

July 23, 2018

FOCALPOINT INTERNATIONAL, INC., Plaintiff,
v.
DOM RUBINO CONSULTING SERVICES, INC.; and BIZSTRATPLAN, INC., Defendants.

          GREENBERG TRAURIG, LLP JACOB D. BUNDICK, ESQ. Counsel for Plaintiff FocalPoint International, Inc.

          LEWIS ROCA ROTHGERBER CHRISTIE LLP DAN R. WAITE, ESQ. ERIK J. FOLEY, ESQ. Counsel for Defendants Dom Rubino Consulting Services, Inc. and BizStratPlan, Inc.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Plaintiff, FocalPoint International, Inc. (“FocalPoint”), and Defendants Dom Rubino Consulting Services, Inc. (“DRCS”) and BizStratPlan Inc. (“BizStratPlan”) (collectively, the “Parties”), by and through their respective counsel of record, and pursuant to Local Rules 7-1 and 26-4, hereby stipulate and agree to extend the deadlines contained in the Discovery Plan and Scheduling Order [Doc. 27] for a period of 60 days for the reasons set forth herein.

         I. DISCOVERY COMPLETED TO DATE

         The Parties have each submitted their initial disclosures. On April 20, 2018, Defendants served their Initial Disclosures Pursuant to FRCP 26(a)(1). On May 24, 2018, FocalPoint Served its Initial Disclosures Pursuant to FRCP 26(a)(1). On June 22, 2018, FocalPoint served its First Supplemental Disclosures. On July 2, 2018, FocalPoint served its Second and Third Supplemental Disclosures.

         The Parties have also served written discovery. On June 1, 2018, Defendants served Requests for Production on FocalPoint. FocalPoint provided its initial response to these Requests on July 2, 2018. Efforts to complete its response remain ongoing. On June 22, 2018, FocalPoint served its First Set of Interrogatories and First Set of Document Requests on both DRCS and BizStratPlan. Defendants' efforts to respond to these discovery requests remain ongoing.

         II. REASONS FOR EXTENDING DEADLINES; GOOD CAUSE

         The Parties have made reasonable efforts in good faith to respond to the respective discovery requests and resolve the case. However, given some unforeseen circumstances, including the Parties' ongoing settlement discussions and the recent addition of a third-party, the Parties have determined that they need a limited extension to allow for full development of the record. The Parties' joint request to extend the deadlines in this matter is made in good faith and good cause exists for such an extension. This request is not made for purposes of delay.

         III. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY

Event

Current Deadline

Proposed New Deadline

Discovery cutoff

September 18, 2018

November 19, 2018

Deadline to amend pleadings

June 20, 2018

August 20, 2018

Deadline for Interim Status Report

July 20, 2018

September 21, 2018

Deadline to make initial expert disclosures

July 20, 2018

September 21, 2018

Deadline to make rebuttal expert disclosures

August 20, 2018

October 19, 2018

Deadline to file dispositive motions

October 18, 2018

December 21, 2018

Deadline to file joint pretrial order

November 19, 2018

January 18, 2019

         Based on the foregoing stipulation and good cause appearing, the Parties respectfully request that the Court enter an Order adopting the Parties' proposed schedule for completing all remaining discovery and deadlines.

         IT IS SO STIPULATED.

         IT ...


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