STIPULATION AND ORDER [PROPOSED] TO STAY DISCOVERY PENDING RESOLUTION OF DEFENDANT'S MOTION TO DISMISS

CARL W. HOFFMAN, Magistrate Judge.

Plaintiff William Tsumpes, an Individual d/b/a T-Energy ("Tsumpes") and Defendant T3 Motion, Inc. ("T3"), by and through the undersigned counsel, hereby stipulate as follows:

WHEREAS, on March 17, 2017, T3 filed a Motion to Dismiss or, Alternatively, to Transfer [ECF No. 9], based on improper venue, the first to file rule, and/or forum non conveniens;

WHEREAS, on April 27, 2017, counsel for the parties met via telephone in accordance with Rule 26(f), during which the parties agreed to stay discovery pending resolution of Defendant's Motion to Dismiss or, Alternatively, to Transfer [ECF No. 9];

WHEREAS, on April 28, 2017, Tsumpes filed his Opposition to the Motion to Dismiss [ECF No. 17];

WHEREAS good cause exists for the requested stay because (1) the discovery stay would promote judicial economy, allow the parties to avoid potentially unnecessary discovery, and reduce the parties' costs. Johnson v. Cheryl, No. 2:11-CV-00291-JCM-CWH, 2013 WL 129383, at *4 (D. Nev. 2013); Aguirre v. S. Nevada Health Dist., No. 2:13-CV-01409-LDG-CWH, 2013 WL 6865710, at *2 (D. Nev. Dec. 30, 2013) (quoting Wagh v. Metris Direct, Inc., 363 F.3d 821, 829 (9th Cir. 2003))]; and (2) when a pending motion raises a threshold legal issue that "do[es] not require further discovery and [is] potentially dispositive of the entire case," this Court has not hesitated to approve a stay of discovery [Yung Lo, 2014 WL 794205, at *3; Aguirre, 2013 WL 6865710, at *2; Thrash v. Towbin Motor Cars, No. 2:13-CV-01216-MMD-CWH, 2013 WL 5969829, at *2 (D. Nev. Nov. 7, 2013); Kidneigh v. Tournament One Corp., No. 2:12-CV-02209-APG-CWH, 2013 WL 1855764, at *2 (D. Nev. May 1, 2013)];

WHEREAS this request is not made for purposes of delay and is supported by good cause;

WHEREAS, if the Court denies the requested discovery stay, the parties will submit a Joint Report, including a proposed Discovery Plan, pursuant to Rule 26(f).

NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, as follows:

Discovery in this matter shall be stayed pending this Court's resolution of T3's Motion to Dismiss [ECF No. 9].

IT IS SO ORDERED.

IT IS FURTHER ORDERED that if the motion to dismiss or, alternatively, to transfer (ECF No. 9) is denied, the parties must meet and confer and file a stipulated discovery plan within 21 days of the date of the order on the motion.