United States District Court, D. Nevada
STANLEY K. ANTHORY, Plaintiff,
PIONEER/MAC, INC., Defendants.
FINLAY & ZAK, LLP R. Samuel Ehlers, Esq., Ramir M.
Hernandez, Esq., BERMAN & RABIN P.A. Benjamin N. Hutnick,
Esq., Admitted Pro Hac Vice Counsel for Defendant Pioneer
Services, sued as Pioneer/Mac, Inc.
STIPULATION FOR EXTENSION OF TIME
to LR 6-1 and LR 26-4, Plaintiff STANLEY K. ANTHORY
(“Plaintiff”) and Defendant PIONEER/MAC, INC.,
(“Defendant”) (collectively, the
“Parties”), by and through their counsel of
record, hereby stipulate and request that this Court extend
the discovery, joinder/amendment, expert disclosure, and
dispositive motion deadlines by 30 days. This is the
Parties' third request to extend the case deadlines since
the Court's first scheduling order. ECF Nos. 12, 14, 29.
In support of this Stipulation and Request, the Parties state
FOR EXTENSION OF TIME
DISCOVERY COMPLETED TO DATE
January 7, 2019, Plaintiff filed his Complaint. ECF No. 1.
April 23, 2019, Defendant filed its Answer to Plaintiff's
Complaint. ECF No. 6.
May 14, 2019, the Court entered the Parties' Proposed
Protective Order. ECF No. 9.
May 19, 2019, Plaintiff propounded its First Set of Requests
for Production and Interrogatories on Defendant.
June 18, 2019, the Court entered the Parties' Proposed
Discovery Plan and Scheduling Order. ECF No. 12.
July 2, 2019, Defendant responded to Plaintiff's First
Set of Requests for Production of Documents and
July 26, 2019 the Parties filed their First Stipulation for
Extension of Time. ECF No. 14.
July 26, 2019, the Court entered the Parties' Proposed
Modified Discovery Plan and Scheduling Order. ECF No. 15.
August 5, 2019 Plaintiff filed his Motion to Compel responses
to Plaintiff's First Set of Requests for Production of
Documents and Interrogatories. ECF No. 17.
August 19, 2019 Defendant filed its Response to
Plaintiff's Motion to Compel responses to Plaintiff's
First Set of Requests for ...