Filed: Nov. 14, 2018
Latest Update: Nov. 14, 2018
Summary: STIPULATION TO STAY DISCOVERY PENDING THE COURT'S DECISIONS THE PENDING MOTION TO DISMISS [ECF NO. 5] [FIRST REQUEST] CAM FERENBACH , Magistrate Judge . Pursuant to Local Rules of Practice for the United States District Court for the District of Nevada (" LR ") IA 6-1, 6-2, and 7-1,; Defendant University Medical Center ("UMC", by through its counsel Matthew T. Dushoff, Esq.; and Plaintiff Grace Thompson (" Plaintiff "), by and through her counsel Leslie M. Stovall, Esq. of the law firm Sto
Summary: STIPULATION TO STAY DISCOVERY PENDING THE COURT'S DECISIONS THE PENDING MOTION TO DISMISS [ECF NO. 5] [FIRST REQUEST] CAM FERENBACH , Magistrate Judge . Pursuant to Local Rules of Practice for the United States District Court for the District of Nevada (" LR ") IA 6-1, 6-2, and 7-1,; Defendant University Medical Center ("UMC", by through its counsel Matthew T. Dushoff, Esq.; and Plaintiff Grace Thompson (" Plaintiff "), by and through her counsel Leslie M. Stovall, Esq. of the law firm Stov..
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STIPULATION TO STAY DISCOVERY PENDING THE COURT'S DECISIONS THE PENDING MOTION TO DISMISS [ECF NO. 5]
[FIRST REQUEST]
CAM FERENBACH, Magistrate Judge.
Pursuant to Local Rules of Practice for the United States District Court for the District of Nevada ("LR") IA 6-1, 6-2, and 7-1,; Defendant University Medical Center ("UMC", by through its counsel Matthew T. Dushoff, Esq.; and Plaintiff Grace Thompson ("Plaintiff"), by and through her counsel Leslie M. Stovall, Esq. of the law firm Stovall and Associates, hereby stipulate and agree, and respectfully request that the Court stay the filing of a Discovery Plan and Scheduling Order required by Fed. R. Civ. P. 26(f) and LR 26-1(d), and the conducting of all discovery in this action, pending this Court's resolution of Defendant UMC's Motion to Dismiss Complaint [ECF No.5]
This instant Stipulation to Stay Discovery Pending the Court's Decisions on the Rule 12 Dismissal Motion, is the Parties' first request to stay the filing of a Discovery Plan and Scheduling Order required by FED. R. CIV. P. 26(f) and LR 26-1, and to stay the conducting of all discovery, in this Action.
Without conceding the merits of the Rule 12 Dismissal Motion the Parties agree that should this Court grant the Rule 12 Dismissal Motion, the Court's decision may be dispositive of this Action, and no further proceedings or discovery by and among the Parties will therefore be required, unless otherwise ordered by this Court. As such, the Parties respectfully suggest that a stay of all further discovery obligations under FED. R. CIV. P. 26(f) and LR 26-1 is warranted, and said stay will preserve valuable judicial resources, party resources, and time pending resolution of the Rule 12 Dismissal Motion.
If the Court denies the Rule 12 Dismissal Motion in whole or in part, the remaining Parties to this Action agree to submit a Discovery Plan and Scheduling Order within thirty (30) calendar days after the date of entry of the Court's Order on the Rule 12 Dismissal Motion. No other parties are affected by this Stipulation.
For the foregoing reasons, the Parties respectfully proffer that good cause exists to grant this Stipulation staying Discovery. The undersigned represent this Stipulation is not intended for purposes of delay.
IT IS SO ORDERED.
