United States District Court, D. Nevada
ROCA ROTHGERBER CHRISTIE LLP E. LEIF REID DARREN J. LEMIEUX
MARLA J. HUDGENS NICOLE SCOTT ATTORNEYS FOR PLAINTIFF
LARSEN & WIXO MCHRISTOPHER L. BENNER AND QUARLES &
BRADY LLP BRIAN A. HOWIE (ADMITTED PRO HAC VICE) KRYSTAL
ASPEY FLEISCHMANN (ADMITTED PRO HAC VICE) MICHAEL S. CATLETT
(ADMITTED PRO HAC VICE) TWO NORTH CENTRAL AVENUE RENAISSANCE
ONE ATTORNEYS FOR DEFENDANT
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES
UNDER ORDER [ECF NO. 135] (FIRST REQUEST)
Bonanza Beverage Co. (“Bonanza”), by and through
its undersigned counsel, and Defendant MillerCoors LLC
(“MillerCoors”), by and through its undersigned
counsel, (collectively, the “Parties”) hereby
stipulate to extend the deadlines under this Court's
Order [ECF No. 135] (“Order”). This is the first
stipulation for extension of time related to the Order, which
is necessitated by a change in the originally scheduled
November 1, 2019, mediation date, to November 13, 2019.
Order resulted from the Parties' Joint Motion to Stay
Discovery [ECF No. 134], where the Parties requested to stay
all discovery in this matter pending their continued
settlement discussions and an upcoming mediation in Las Vegas
that was originally scheduled for November 1, 2019. See
Id. The Court granted the stay in part, and ordered the
Parties “to submit a status report regarding the
outcome of th[e] mediation no later than November 7, 2019 . .
. .” [ECF No. 135.] The Court further ordered that
“discovery in this matter shall be stayed until and
through November 7, 2019.” Id.
Parties now inform the Court that, because of availability of
the principals, the mediation date was moved to November 13,
2019. The Parties stipulate and are therefore requesting that
the Order's deadlines be extended accordingly as
described below. As grounds for this relief, the Parties
provide the Court with a summary of the status of discovery
and argument in support of a stay.
Discovery that has been completed.
Parties served their initial disclosures on September 24,
2018, and each side has timely supplemented those
Bonanza served its first set of discovery requests on
September 28, 2018.
MillerCoors served its first set of discovery requests on
October 19, 2018.
MillerCoors served its responses to Bonanza's first set
of discovery requests on October 29, 2018 and supplemented
those responses on November 19, 2018 and February 14, 2019.
Bonanza served its responses to MillerCoors first set of
discovery requests on November 19, 2018 and supplemented
those responses on December 18, 2018 and January 31, 2019.
Parties served initial expert disclosures on December 14,
Parties served and received responses to subpoenas duces