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Anthory v. Pioneer/Mac, Inc.

United States District Court, D. Nevada

November 5, 2019

STANLEY K. ANTHORY, Plaintiff,
v.
PIONEER/MAC, INC., Defendants.

          WRIGHT 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

         Pursuant 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 as follows:

         STIPULATION FOR EXTENSION OF TIME

         A. DISCOVERY COMPLETED TO DATE

         1. On January 7, 2019, Plaintiff filed his Complaint. ECF No. 1.

         2. On April 23, 2019, Defendant filed its Answer to Plaintiff's Complaint. ECF No. 6.

         3. On May 14, 2019, the Court entered the Parties' Proposed Protective Order. ECF No. 9.

         4. On May 19, 2019, Plaintiff propounded its First Set of Requests for Production and Interrogatories on Defendant.

         5. On June 18, 2019, the Court entered the Parties' Proposed Discovery Plan and Scheduling Order. ECF No. 12.

         6. On July 2, 2019, Defendant responded to Plaintiff's First Set of Requests for Production of Documents and Interrogatories.

         7. On July 26, 2019 the Parties filed their First Stipulation for Extension of Time. ECF No. 14.

         8. On July 26, 2019, the Court entered the Parties' Proposed Modified Discovery Plan and Scheduling Order. ECF No. 15.

         9. On 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.

         10. On August 19, 2019 Defendant filed its Response to Plaintiff's Motion to Compel responses to Plaintiff's First Set of Requests for ...


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