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LLC v. Paris Las Vegas Operating Co., LLC

United States District Court, D. Nevada

March 18, 2019

TPOV ENTERPRISES 16, LLC, a Delaware Limited Liability Company, Plaintiff,
v.
PARIS LAS VEGAS OPERATING COMPANY, LLC, a Nevada limited liability company, Defendant. PARIS LAS VEGAS OPERATING COMPANY, LLC, a Nevada limited liability company, Counterclaimant.
v.
TPOV ENTERPRISES, LLC, a Delaware Limited Liability Company, TPOV ENTERPRISES 16, LLC, a Delaware Limited Liability Company, Rowen Siebel, an individual. Counter-defendants.

          Pisanelli Bice pllc MCNUTT LAW FIRM, PC., James J. Pisanelli, Esq., Bar No. 4027 Debra L. Spinelli, Esq., Bar No. 9695 M. Magali Mercera, Esq., Bar No. 11742 Brittnie T. Watkins, Esq., Bar No. 13612 Attorneys for Paris Las Vegas Operating Company, LLC

          MCNUTT LAW FIRM, P.C. Dan McNutt, Esq., Bar No. 7815 Matthew Wolf, Esq., Bar No. 10801 CERTILMAN BALIN ADLER & HYMAN, LLP

          Paul Sweeney, Esq. (admitted pro hac vice) Joshua Feldman, Esq. (admitted pro hac vice) Nicole Milone, Esq. (admitted pro hac vice) Attorneys for TPOV Enterprises 16, LLC, TPOV Enterprises, LLC and Rowen Seibel

          STIPULATION AND ORDER TO EXTEND DISCOVERY (SIXTH REQUEST)

         Plaintiff/Counterdefendants TPOV Enterprises 16, LLC ("TPOV 16"), TPOV Enterprises, LLC ("TPOV"), and Rowen Seibel ("Seibel") and Defendant/Counterclaimant Paris Las Vegas Operating Company, LLC ("Paris") by and through their undersigned counsel of record, request an order modifying the parties' Joint Discovery Plan and Scheduling Order, (ECF No. 17), as amended November 3, 2017 (ECF No. 47), May 10, 2018 (ECF No. 55), November 13, 2018 (ECF No. 68), and February 6, 2019 (ECF 84). This is the sixth stipulation to extend discovery. In compliance with LR IA 6-1 and LR 26-4, the parties submit as follows:

         1. STATEMENT OF DISCOVERY COMPLETED TO DATE.

• The parties both served their initial disclosures on June 12, 2017.
• Paris served its first supplemental disclosures on June 14, 2017.
• TPOV 16 served its first supplemental disclosures on June 20, 2017.
• On September 22, 2017, the parties exchanged proposed search terms for electronic discovery.
• On October 4, 2017, the parties met and conferred on proposed search terms.
• On October 12, 2017, the parties exchanged revised search terms for electronic discovery.
• On October 12, 2017, the parties met and conferred on revisions to the proposed search terms.
• On October 23, 2017, TPOV 16 provided further revisions to search terms for electronic discovery.
• On October 31, 2017, Paris represented to TPOV 16 that Paris would be proceeding with running TPOV 16's search terms for electronic discovery and would present preliminary results to TPOV 16 in the near future.
• On November 9, 2017 TPOV 16 served its First Set of Request for Production of Documents on Paris.
• On December 4, 2017 TPOV 16 served its First Set of Interrogatories on Paris.
• On December 13, 2017, Paris served its Reponses to TPOV 16's First Set of Request for Production of Documents.
• On January 9, 2017, Paris served its Responses to TPOV 16's First Set of Interrogatories.
• On January 16, 2018, TPOV 16 issued a subpoena to third-party Trisha Thompson. . On January 16, 2018, TPOV 16 issued a subpoena to third-party Markita Thompson.
• On February 1, 2018, Trisha Thompson served her objections to TPOV 16's subpoena.
• On February 1, 2018, Markita Thompson served her objections to TPOV 16's subpoena.
• On February 9, 2018, Paris requested additional revisions to the proposed search terms due to the volume of results.
• On February 12, 2018, TPOV 16 provided further revisions to search terms for electronic discovery.
• On February 22, 2018, Paris proposed categories of documents to respond to TPOV ...

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