United States District Court, D. Nevada
S. Larsen, Esq., Jing Zhao, Esq., Wing Yan Wong, Esq., GORDON
REES SCULLY MANSUKHANI, LLP Attorneys for eTouch Menu, Inc.
and Scott Morrow
Bragonje, Esq., Jennifer K. Hostetler, Esq., Brian D.
Blakeley, Esq., LEWIS ROCA ROTHGERBER CHRISTIE LLP Attorneys
for eTouch LV, LLC
THOMAS EDWARDS, ESQ., HOLLEY DRIGGS WALCH FINE WRAY PUZEY
& THOMPSON Attorneys for eTouch Menu, Inc. and Scott
STIPULATION AND ORDER TO STAY DISCOVERY PENDING
eTouch LV, LLC and Defendants/Counterclaimants eTouch Menu,
Inc. and Scott Morrow (collectively as
“Parties”), by and through their respective
counsel, hereby stipulate and respectfully request that the
Court stay discovery pending completion of the parties'
private mediation currently scheduled for August 21-22, 2019
with (Ret.) Judge Philip Pro of JAMS. The Parties believe the
proposed stay is in the Parties' and the Court's
interests of costs and efficiency.
support of this request, the Parties provide the following
information for the Court's consideration:
action includes competing claims filed by eTouch LV, LLC, on
the one hand, and eTouch Menu, Inc. and Scott Morrow, on the
other. See ECF No. 54, 56. Additionally, this
dispute also includes an arbitration pending before the
American Arbitration Association. See ECF No. 55.
Parties have engaged in substantial discovery including but
not limited to the following:
a. The Parties exchanged their initial disclosures.
b. eTouch Menu served its first set of requests for
production on eTouch LV, LLC. eTouch LV, LLC served its
responses to the same.
c. eTouch LV, LLC served its first set of requests for
admission, requests for production, and interrogatories on
eTouch Menu, Inc. eTouch Menu, Inc. served its responses to
d. eTouch LV, LLC served its first set of requests for
production and interrogatories on Scott Morrow. Scott Morrow
served his responses to the same.
e. eTouch Menu recently served its second set of requests for
production to eTouch LV, LLC. eTouch LV, LLC's responses
are not yet due.
f. Scott Morrow recently served his first set of
interrogatories to eTouch LV, LLC. eTouch LV, LLC's
responses are not yet due.
g. Collectively, the Parties have produced approximately 2.5
million pages of documents. h. The Parties are meeting and
conferring regularly regarding several discovery issues. i.
eTouch LV, LLC served its notice of intent to serve subpoenas
for documents on twenty (20) third ...