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Hinton v. Price Zone

United States District Court, D. Nevada

November 15, 2019

YOKO HINTON Plaintiff,
v.
PRICE ZONE dba J & S INTERNATIONAL ALPHA, GAS ONE and/or GAS ONE/ALPHA, a Foreign Corporation; ROE “ALPHA” MANUFACTURER, an entity of unknown origin; ROE MANUFACTURERS and/or DISTRIBUTORS; DOES I through XXX, inclusive and ROE BUSINESS ENTITIES I through XXX, inclusive, Defendants.

          LADAH LAW FIRM RAMZY P. LADAH, ESQ. JOSEPH C. CHU, ESQ. ATTORNEY FOR PLAINTIFF

          LEWIS BRISBOIS BISGAARD & SMITH LLP DARRELL D. DENNIS, ESQ. STEVEN ABBOTT, ESQ. ATTORNEY FOR DEFENDANT

          STIPULATION TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         Pursuant to LR 26-3 and the scheduling order (Doc. 8) in this matter, Defendant PRICE ZONE d/b/a J & S INTERNATIONAL (“PRICE ZONE” or “Defendant”), incorrectly named in the caption as PRICE ZONE dba J&S INTERNATIONAL, ALPHA, GAS ONE and/or GAS ONE/ALPHA, by and through its attorneys, LEWIS BRISBOIS BISGAARD & SMITH LLP, and Plaintiff, YOKO HINTON (“Plaintiff”) by and through her attorneys of record, of the law firm LADAH LAW FIRM (Collectively, “the Parties”) hereby respectfully submit their Stipulation and Order to Extend Time for Discovery (First Request) pursuant Rules 6(b) and 26(f) of the Federal Rules of Civil Procedure and Local Rules 6-1 and 26-4.

         This is the Parties' First Request for an Extension of Time, and the same is not brought for purposes of delay, but rather for the sole purpose of allowing the parties to diligently and adequately prepare their respective cases for either settlement discussions or trial.

         This stipulation is brought in compliance with LR 26-4 as it is filed more than 21 days before the expiration of Plaintiff's Initial Expert Disclosure deadline. Due to certain complexities in this case the parties jointly request at 60-day extension of the deadline for initial expert disclosures, rebuttal expert disclosures, and deadline to file motion(s) to add parties or amend pleading.

         REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE DEADLINES CONTAINED IN THE DISCOVERY SCHEDULING ORDER

         The extension is sought for the following reasons:

         The Parties are in the process of working together to determine whether the allegedly-defective product at issue is indeed one which was allegedly distributed by Defendant PRICE ZONE. Although Plaintiff brought this action against PRICE ZONE in good faith and based on credible information regarding the manufacturer's identity, additional information since unveiled now raises questions as to the accuracy of this original indication. Accordingly, rather than exhaust potentially needless time and resources on further discovery (particularly that relating to damages), the parties hereby request a brief extension of the current discovery deadlines so that the parties can complete their investigation of the product's identity before proceeding with additional discovery.

         To date, the parties have exchanged Rule 26.1(a)(1) disclosures, and supplemented as needed. The Defendant has also propounded and Plaintiff responded to written discovery requests. Currently, Plaintiff's deposition is scheduled to be completed on December 18, 2019.

         IT IS HEREBY STIPULATED AND AGREED to by the Parties that the discovery deadlines in this matter be continued for a period of 60 days to allow the parties additional time to complete discovery, and retain and disclose experts.

         STATEMENT SPECIFYING THE DISCOVERY THAT HAS BEEN COMPLETED.

         1. The parties participated in the Fed.R.Civ.P 26(f) conference;

         2. All parties have made their disclosures pursuant to ...


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