Filed: Aug. 15, 2019
Latest Update: Aug. 15, 2019
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE AMENDED JOINT PROPOSED DISCOVERY PLAN AND SCHEDULING ORDER (First Request) NANCY J. KOPPE , Magistrate Judge . Defendant J.C.M. Industries, Inc. doing business as Advance Storage Products ("JCM"), by and through its counsel, Jackson Lewis P.C., Plaintiffs Quinton Drummer, Steffan Webb and Demontray Stallworth ("Plaintiffs"), by and through their counsel, Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP, and Defendant Hector Beltran, in proper perso
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE AMENDED JOINT PROPOSED DISCOVERY PLAN AND SCHEDULING ORDER (First Request) NANCY J. KOPPE , Magistrate Judge . Defendant J.C.M. Industries, Inc. doing business as Advance Storage Products ("JCM"), by and through its counsel, Jackson Lewis P.C., Plaintiffs Quinton Drummer, Steffan Webb and Demontray Stallworth ("Plaintiffs"), by and through their counsel, Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP, and Defendant Hector Beltran, in proper person..
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STIPULATION AND ORDER TO EXTEND TIME TO FILE AMENDED JOINT PROPOSED DISCOVERY PLAN AND SCHEDULING ORDER
(First Request)
NANCY J. KOPPE, Magistrate Judge.
Defendant J.C.M. Industries, Inc. doing business as Advance Storage Products ("JCM"), by and through its counsel, Jackson Lewis P.C., Plaintiffs Quinton Drummer, Steffan Webb and Demontray Stallworth ("Plaintiffs"), by and through their counsel, Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP, and Defendant Hector Beltran, in proper person, hereby submit this stipulation to extend to submit their joint proposed discovery plan and scheduling order.
Plaintiffs served their First Amended Collective and Class Action Complaint on JCM on July 5, 2019, adding JCM as a Defendant to this action. The parties stipulated to extend JCM's deadline to answer or otherwise respond to Plaintiff's First Amended Collective and Class Action Complaint to August 26, 2019. The parties believe that more meaningful discussions regarding scope of discovery may be had after the filing of JCM's responsive pleading. The parties seek an extension through and including September 9, 2019 to file their proposed Discovery Plan and Scheduling Order. This extension will provide the parties with two weeks to confer regarding the scope of discovery based on JCM's responsive pleading and any defenses asserted.
STIPULATION
NOW THEREFORE, the parties hereby agree and stipulate as follows:
The deadline for filing the parties' Amended Joint Proposed Discovery Plan and Scheduling order be continued to September 9, 2019. This stipulation and order is sought in good faith and not for the purpose of delay.
Dated this 14th day of August, 2019.
WOLF, RIFKIN, SHAPRIO, SCHULMAN JACKSON LEWIS P.C.
& RABKIN, LLP
/s/Charles R. Ash, IV /s/ Daniel I. Aquino
Don Springmeyer, Bar No. 1021 Kirsten A. Milton, Bar No. 14401
Bradley S. Schrager, Bar No. 10217 Daniel I. Aquino, Bar No. 12682
Daniel Bravo, Bar No. 13078 300 S. Fourth Street, Suite 900
3556 E. Russell Road, Second Floor Las Vegas, Nevada 89101
Las Vegas, Nevada 89102 Attorneys for Defendant J.C.M. Industries, Inc.
dba Advance Storage Products
Charles R. Ash, IV, Pro Hac Vice
Sommers Schwartz, P.C.
One Towne Square, 17th Floor
Southfield, Michigan 48076
Attorneys for Plaintiffs
/s/Hector Beltran
Hector Beltran
BG Construction Services, LLC
9775 Hightower Road
Roswell, GA 30075
Defendant, in proper person
IT IS SO ORDERED.
