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Parsons v. Colt's Manufacturing Company LLC

United States District Court, D. Nevada

September 30, 2019

JAMES PARSONS, et al., Plaintiffs,
v.
COLT'S MANUFACTURING COMPANY LLC; et al., Defendants.

          MATTHEW L. SHARP, LTD. MATTHEW L. SHARP, ESQ., RICHARD H. FRIEDMAN, ESQ. Rubin PLLP, Joshua D. Koskoff (Admitted PHV) Admitted PHV Katherine L Messner-Hage (Admitted PHV) KOSKOFF, KOSKOFF & BIEDER, PC Attorneys for Plaintiffs

          EVANS FEARS & SCHUTTERT LLP Jay J. Schuttert, Alexandria L. Layton Counsel for Defendants Colt's Manufacturing Company, LLC, Colt Defense, LLC, Christensen Arms, Lewis Machine & Tool Company, and LWRC International, LLC

          Bryon J. Benevento (Applying Pro Hac Vice) Dorsey & Whitney, LLP Counsel for Defendant Christensen Arms

          John F. Renzulli (Applying Pro Hac Vice) Christopher Renzulli (Applying Pro Hac Vice), Scott C. Allan (Applying Pro Hac Vice) Renzulli Law Firm, LLP Counsel for Defendants Colt's Manufacturing Company, LLC, Colt Defense, LLC, Lewis Machine & Tool Company, and LWRC International, LLC

          SNELL & WILMER LLP /s/ V.R. Bohman_ Patrick G. Byrne V.R. Bohman (Nev. #13075)Counsel for Defendants Daniel Defense, Inc., Patriot Ordnance Factory, and Sportsman's Warehouse

          PISCIOTTI MALSCH Anthony Pisciotti (Applying Pro Hac Vice), Ryan Erdreich (Applying Pro Hac Vice) Counsel for Defendant Noveske Rifleworks, LLC

          THE AMIN LAW GROUP, LTD. Ismail Amin, Christopher M. Chiafullo (Applying Pro Hac Vice) The Chiafullo Group, LLC Counsel for Defendants Discount Firearms and Ammo, LLC, DF&A Holdings, LLC, and Maverick Investments, LP

          MURCHISON & CUMMING, LLP Michael Nunez James Vogts (Applying Pro Hac Vice) Swanson, Martin & Bell LLP Counsel for Defendant Guns & Guitars, Inc.

          SPENCER FANE LLP John H. Mowbray, Mary E. Bacon, Jessica Chong, Camden R. Webb (Pro Hac Vice), Robert C. Van Arnam (Pro Hac Vice), Justin S. Feinman (Pro Hac Vice), Turner A. Broughton (Pro Hac Vice) Counsel for Defendant FN America

          STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF MOTIONS TO DISMISS

         Plaintiffs James and Ann-Marie Parsons (“Plaintiffs”) and Defendants Colt's Manufacturing Company LLC; Colt Defense LLC; Daniel Defense Inc.; Patriot Ordnance Factory, Inc.; FN America; Noveske Rifleworks LLC; Christensen Arms; Lewis Machine & Tool Company; LWRC International LLC; Discount Firearms and Ammo LLC; DF&A Holdings LLC; Maverick Investments LP; Sportsman's Warehouse, Inc.; and Guns and Guitars Inc. (“Defendants, ” and together with Plaintiffs, the “Parties”) by and through their respective counsel, hereby stipulate that all discovery deadlines and obligations, including those found in Federal Rule of Civil Procedure 26, be stayed pending resolution of Defendants' Motions to Dismiss set to be filed on September 24, 2019 per this Court's prior orders, ECF Nos. 25 and 60. This stipulation is requested by the Parties in good faith and not for the purposes of delay, but in the interest of efficiency. This is the first request to stay discovery.

         The Parties agree that good cause exists to stay discovery because Defendants' Motions to Dismiss are potentially dispositive of the entire case. Staying discovery until these Motions are decided promotes efficiency, avoiding unnecessary costs in time and treasure. If the operative complaint survives the Motions to Dismiss, the parties agree that thirty (30) days from the notice of entry of the Court's order will provide sufficient time to coordinate the various Parties' schedules and conduct a Rule 26(f) conference.

         For these reasons, the parties respectfully request that the Court enter an Order as follows:

         1) Staying all discovery, including all discovery deadlines, pending the resolution of Defendants' Motions to Dismiss set to be filed on September 24, 2019;

         2) If the original complaint survives Defendants' Motions to Dismiss, the deadline to hold the Rule 26(f) conference is extended to thirty (30) days from entry of the ...


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