United States District Court, D. Nevada
LAW FIRM RAMZY P. LADAH, ESQ. JOSEPH C. CHU, ESQ. ATTORNEY
BRISBOIS BISGAARD & SMITH LLP DARRELL D. DENNIS, ESQ.
STEVEN ABBOTT, ESQ. ATTORNEY FOR DEFENDANT
STIPULATION TO EXTEND DISCOVERY DEADLINES (FIRST
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.
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.
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.
WHY THE DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE
DEADLINES CONTAINED IN THE DISCOVERY SCHEDULING
extension is sought for the following reasons:
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
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.
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.
SPECIFYING THE DISCOVERY THAT HAS BEEN
parties participated in the Fed.R.Civ.P 26(f) conference;
parties have made their disclosures pursuant to ...