United States District Court, D. Nevada
FENNEMORE CRAIG, P.C., Richard Dreitzer, Esq., NV Bar No.
6626 Daniel S. Cereghino, Esq., NV Bar No. 11534 Attorneys
KENNEDY Joseph A. Liebman, Esq., NV Bar No. 10125 LAW OFFICE
OF MICHAEL LATER Michael M. Later, Esq., NV Bar No. 7416
Attorneys for the Growth Defendants
STIPULATION AND ORDER [PROPOSED] REGARDING EXTENSIONS
OF TIME: (1) TO FILE RESPONSE AND REPLY TO MOTION TO DISMISS
[ECF NO. 70]; AND (2) TO MAKE INITIAL DISCLOSURES PURSUANT TO
JOINT DISCOVERY PLAN [ECF NO. 71]
Nikkei Global Inc. (“NGI”), and Defendants
Phillippe Ziade, Jude Nassar, Appleton Properties, LLC, Z Leb
Group, LLC, Progressive Construction, Inc., Growth
Development, LLC, Vibrant Realty, LLC, AJ Properties
International, LLC, AJ Properties International Series 2,
LLC, Growth Holdings, LLC, Growth Luxury Homes LLC, and
Growth Luxury Realty, LLC (collectively, the “Ziade
Defendants”), by and through their undersigned
respective counsel, submit the following Stipulation for the
Court's review and approval.
ZIADE DEFENDANTS' NEW MOTION TO DISMISS [ECF No.
October 28, 2019, following this Court's dismissal of
some but not all of Plaintiff NGI's claims (see
Order, ECF No. 68), the Ziade Defendants filed another Motion
to Dismiss the remainder of Plaintiff NGI's First Amended
Complaint, this time on purely jurisdictional grounds.
See ECF No. 70. The original deadline for NGI to
file its Response to the Ziade Defendants' new Motion to
Dismiss was November 11, 2019. See LR 7-2(b). Prior
to that date, however, NGI requested additional time to
prepare and file its Response, and the Ziade Defendants
agreed to such request. The Parties agreed that the new
deadline should be November 25, 2019. The Parties also agreed
that the new deadline for Ziade Defendants' for their
Reply is December 13, 2019.
THE PARTIES' INITIAL DISCLOSURES
October 25, 2019, the Parties submitted their proposed Joint
Discovery Plan for this Court's approval. See
ECF No. 69. On October 30, 2019, this Court approved that
originally submitted plan. See ECF No. 71. The
Parties have subsequently agreed, however, that the date for
initial disclosures should be extended to December 9, 2019.
All other dates in the Plan remain the same and are
unaffected by this Stipulation to extend the initial
such, the Parties stipulate as follows:
Plaintiff NGI shall have until and through November 25, 2019
to file its Response to the Ziade Defendants' new and
pending Motion to Dismiss [ECF No. 70];
Ziade Defendants' shall have until and through December
13, 2019 to file its Reply to NGI's Response to the Ziade
Defendants' new and pending Motion to Dismiss [ECF No.
Parties shall have until and through December 9, 2019, to
make their initial disclosures (with no other dates in the
Plan being changed at this time).