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Sandoval v. Drybar Holdings, LLC

United States District Court, D. Nevada

November 18, 2019

SHANE MICHAEL SANDOVAL, an individual, Plaintiff,
v.
DRYBAR HOLDINGS LLC, a foreign limited liability company; HUNTER JOHNSON, in individual, RENEE ATWOOD, an individual, PATRICE CAMPBELL, an individual, ZENA LONG, an individual, KATOYA SHAW, AN INDIVIDUAL, RACHEL BERNARD, an individual; and DOES 1 through 100, inclusive, Defendants.

          WENDY MEDURA KRINCEK, ESQ., Bar # 6417 MARCUS B. SMITH, ESQ., Bar # 12098 LITTLER MENDELSON, P.C. Attorneys for Defendants DRYBAR HOLDINGS LLC, HUNTER JOHNSON, RENEE ATWOOD, PATRICE CAMPBELL, ZENA GARDNER, KATOYA SHAW, and RACHEL BERNARD

          KEEN L. ELLSWORTH, ESQ. ELLSWORTH & BENNION, CHTD. Attorneys for Plaintiff SHANE MICHAEL SANDOVAL

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES [SECOND REQUEST]

         Plaintiff, SHANE MICHAEL SANDOVAL and Defendants, DRYBAR HOLDINGS LLC, HUNTER JOHNSON, RENEE ATWOOD, PATRICE CAMPBELL, ZENA GARDNER, AND RACHEL BERNARD, by and through their respective counsel of record, do hereby stipulate and agree to amend the current scheduling order and discovery plan (ECF No. 67) by extending the current discovery cut-off date of January 6, 2020 for an additional 90 days until April 6, 2020 (April 5, 2020 is a Sunday), with other discovery dates extended as set forth below.

         DISCOVERY COMPLETED TO DATE

         To date, the parties have completed the following discovery:

         Plaintiff:

Plaintiff:

Initial Disclosures

May 23, 2019

Responses to Defendant's Requests for Production

June 27, 2019

Responses to Defendant's Interrogatories

June 27, 2019

First Supplement to Initial Disclosures

June 27, 2019

Requests for Production to Drybar

July 26, 2019

Interrogatories to Drybar

July 26, 2019

Requests for Production to Johnson

July 26, 2019

Interrogatories to Johnson

July 26, 2019

Requests for Production to Atwood

July 26, 2019

Interrogatories to Atwood

July 26, 2019

Requests for Production to Campbell

July 26, 2019

Interrogatories to Campbell

July 26, 2019

Requests for Production to Gardner

July 26, 2019

Interrogatories to Gardner

July 26, 2019

Requests for Production to Bernard

July 26, 2019

Interrogatories to Bernard

July 26, 2019

Notice of Subpoena to Navex Global

August 20, 2019

Notice of Subpoena to Ogleetree Deakins Nash & Smoak

August 20, 2019

Second Supplement to Initial Disclosures

October 23, 2019

Defendant:

Initial Disclosures

May 28, 2019

Requests for Production to Plaintiff

May 28, 2019

Interrogatories to Plaintiff

May 28, 2019

Responses to Requests for Production to Drybar

October 25, 2019

Responses to Interrogatories to Drybar

October 25, 2019

Responses to Requests for Production to Johnson

October 25, 2019

Responses to Interrogatories to Johnson

October 25, 2019

Responses to Requests for Production to Atwood

October 25, 2019

Responses to Interrogatories to Atwood

October 25, 2019

Responses to Requests for Production to Campbell

October 25, 2019

Responses to Interrogatories to Campbell

October 25, 2019

Responses to Requests for Production to Gardner

October 25, 2019

Responses to Interrogatories to Gardner

October 25, 2019

Responses to Requests for Production to Bernard

October 25, 2019

Responses to Interrogatories to Bernard

October 25, 2019

         DISCOVERY TO BE COMPLETED

         The parties anticipate the taking of several depositions, including Plaintiff's deposition, Defendants' depositions, and witnesses identified by both parties. The parties also intend to serve additional third party subpoenas. In addition, the parties are in the meet and confer process regarding Plaintiff's responses to interrogatories and requests for production of documents and third party subpoenas.

         REASONS FOR EXTENSION TO COMPLETE DISCOVERY

         Good cause exists for the requested extension due to the number of parties in this action, and the fact that the parties intend to depose all parties, additional time is needed to accommodate the various depositions. Some of the anticipated deponents reside out of state. The parties also need additional time to resolve discovery disputes. In addition, Defendant Shaw was recently served and appeared in this matter on October 1, 2019, and may serve or need to respond to written discovery prior to depositions. This is the second stipulation for extension of the discovery deadline and it is sought in good faith and not for the purpose of delay.

         PROPOSED SCHEDULE

         1. ...


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