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McNamara v. Hallinan

United States District Court, D. Nevada

May 14, 2019

THOMAS W. MCNAMARA, as the Court-Appointed Monitor for AMG Capital Management, LLC; BA Services LLC; Black Creek Capital Corporation; Broadmoor Capital Partners, LLC; Park 269, LLC; C5 Capital LLC; DF Services Corp.; DFTW Consolidated [UC LLC; Impact BP LLC; Level 5 Apparel LLC; Level 5 Capital Partners LLC; Level 5 Eyewear LLC; Level 5 Motorsports, LLC; Level 5 Scientific LLC; NM Service Corp. f/k/a/ National Money Service; PSB Services LLC; Real Estate Capital LLC f/k/a/ Rehab Capital I, LLC; Sentient Technologies; ST Capital LLC; Westfund LLC; Eclipse Renewables Holdings LLC; Scott Tucker Declaration of Trust, dated February 20, 2015; West Race Cars, LLC; and Level 5 Management LLC; and their successors, assigns, affiliates, and subsidiaries, Plaintiff,
v.
LINDA HALLINAN, an individual; CAROLYN HALLINAN, an individual; DOES I-X; and ROE CORPORATIONS I-X, Defendants.

          Lawrence J. Semenza, III, Esq., Bar No. 7174 Christopher D. Kircher, Esq., Bar No. 11176 Jarrod L. Rickard, Esq., Bar No. 10203 SEMENZA KIRCHER RICKARD Attorneys for Defendant Carolyn Hallinan

          McNamara Smith LLP By: s/ Cornelia J.B. Gordon Logan D. Smith (Pro Hac Vice) Edward Chang (NV 11783) Cornelia J. B. Gordon (Pro Hac Vice) Michael F. Lynch (NV 8555) Lynch Law Practice, PLLC Attorneys for Court-Appointed Monitor, Thomas W. McNamara

          Semenza Kircher Rickard By: s/ Jarrod L. Rickard Lawrence J. Semenza, III (NV 7174) Christopher D. Kircher (NV 11176) Jarrod L. Rickard (NV 10203) Adam J. Petitt (Pro Hac Vice) Stradley Ronon Stevens & Young, LLP Attorneys for Defendant Carolyn Hallinan

          JOINT STIPULATION AND ORDER TO AMEND THE DISCOVERY PLAN AND SCHEDULING ORDER (FIFTH REQUEST)

          Brenda Weksler United States Magistrate Judge

         Defendant Carolyn Hallinan and Plaintiff hereby stipulate and agree to an extension to the dates and deadlines set forth in the discovery plan and scheduling order (ECF No. 27, as amended, ECF Nos. 39, 67, 75).[1] The earliest deadline set forth in the current Scheduling Order is the fact discovery cutoff date of May 24, 2019. ECF No. 75. On May 3, 2019, Defendant filed a motion to amend the discovery schedule in the present case (ECF Nos. 81-82) and in the related case of McNamara v. Charles Hallinan, et al., No. 2:17-cv-02966-GMN-NJK (See ECF No. 88 therein.). Plaintiff opposed both motions. In the Charles Hallinan matter, Defendant's motion was granted (See ECF No. 91 therein) and, among other deadlines, fact discovery was extended to June 30, 2019. A copy of the Order Granting Defendant's Motion to Extend in the Charles Hallinan matter is attached hereto as Exhibit A. The parties now respectfully request that the same extension be granted in the present action. . The parties have requested previous extensions of the discovery scheduling order.

         Pursuant to Fed.R.Civ.P. 16(b)(4), LR IA 6-1, LR IA 6-2, and LR 26-4, Defendant Carolyn Hallinan and Plaintiff stipulate to extend certain dates included in the Court's Scheduling Order regarding this case's discovery plan.

         Completed Discovery

         The following discovery has occurred:

         Plaintiff has served Defendants with the following items:

1. Initial Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1);
2. First Set of Interrogatories;
3. Second Set of Interrogatories;
4. First Set of Requests for Production of ...

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