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Reed v. Convergent Outsourcing, Inc., 2:18-cv-00146-JAD-CWH. (2018)

Court: District Court, D. Nevada Number: infdco20180806a33 Visitors: 46
Filed: Aug. 03, 2018
Latest Update: Aug. 03, 2018
Summary: STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES [First Request] CARL W. HOFFMAN , Magistrate Judge . Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case ninety (90) days, up to and including December 4, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days, as outlined
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STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES

[First Request]

Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case ninety (90) days, up to and including December 4, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days, as outlined herein. In support of this Stipulation and Request, the parties state as follows:

A. Discovery Completed to Date.

1. Plaintiff filed his Complaint on January 26, 2018. 2. Defendant Comcast Enterprise Services, LLC filed its Answer on March 6, 2018. 3. Defendant Convergent Outsourcing, Inc. filed its Answer on March 22, 2018. 4. Defendant Comcast Enterprise Services, LLC served its initial disclosure on April 13, 2018. 5. Defendant Convergent Outsourcing, Inc. served its initial disclosure on April 20, 2018. 6. Plaintiff Robert Reed served his initial disclosure on May 20, 2018.

B. Specific Description of Discovery that Remains to be Completed.

1. Completion of written discovery and document productions. 2. Depositions of Plaintiff, Defendant Convergent Outsourcing, Inc., and Defendant Comcast Enterprise Services, LLC. 3. Depositions of any remaining witnesses.

C. Reasons Why the Remaining Discovery was not Completed.

The parties aver, pursuant to LR6-1, good cause exists for requested extension. The parties have been, and continue to make diligent efforts to settle this matter. The parties agree the current deadlines restrict all parties from potentially settling this matter and conducting the remaining necessary discovery.

D. Proposed Discovery Deadlines.

Event Current Deadline Proposed New Deadline Close of Discovery September 4, 2018 December 3, 2018 Dispositive Motions October 4, 2018 January 2, 2019 Pretrial Order November 5, 2018 February 3, 2019

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.

Source:  Leagle

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