Filed: May 14, 2019
Latest Update: May 14, 2019
Summary: STIPULATION AND ORDER TO EXTEND TIME TO HOLD RULE 26 CONFERENCE AND TO SUBMIT STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER (First Request) CAM FERENBACH , Magistrate Judge . Plaintiff/Counter-defendants International Payment Advisors LTD and Marc Maxwell, by and through their counsel of record, Kravitz, Schnitzer & Johnson, Chtd., and Glaser Weil Fink Howard Avchen & Shapiro LLP, and Defendant/Counterclaimant Global Merchant Advisors, LLC, f/k/a Paysafe Services (US) LLC, by and through
Summary: STIPULATION AND ORDER TO EXTEND TIME TO HOLD RULE 26 CONFERENCE AND TO SUBMIT STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER (First Request) CAM FERENBACH , Magistrate Judge . Plaintiff/Counter-defendants International Payment Advisors LTD and Marc Maxwell, by and through their counsel of record, Kravitz, Schnitzer & Johnson, Chtd., and Glaser Weil Fink Howard Avchen & Shapiro LLP, and Defendant/Counterclaimant Global Merchant Advisors, LLC, f/k/a Paysafe Services (US) LLC, by and through i..
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STIPULATION AND ORDER TO EXTEND TIME TO HOLD RULE 26 CONFERENCE AND TO SUBMIT STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER
(First Request)
CAM FERENBACH, Magistrate Judge.
Plaintiff/Counter-defendants International Payment Advisors LTD and Marc Maxwell, by and through their counsel of record, Kravitz, Schnitzer & Johnson, Chtd., and Glaser Weil Fink Howard Avchen & Shapiro LLP, and Defendant/Counterclaimant Global Merchant Advisors, LLC, f/k/a Paysafe Services (US) LLC, by and through its counsel of record, the law firm of Greenberg Traurig, LLP, hereby stipulate and request that the Court enter an order briefly extending the time for the parties to hold the FRCP 26(f) conference from May 30, 2019 to June 4, 2019, with the parties' discovery plan and scheduling order being due on June 18, 2019, to permit Defendant/Counterclaimant to review Plaintiff/Counter-defendants' response to the counterclaims (due May 30, 2019) prior to the June 4, 2019, Rule 26 conference.
This stipulation is made and based upon the following:
1. Plaintiff/Counter-defendants filed the original complaint in this matter on February 1, 2019. ECF No. 1;
2. Defendant/Counterclaimant filed its answer and counterclaims on April 29, 2019. ECF No. 28;
3. Per the parties' stipulation, Plaintiff/Counter-defendants have up to, and including, May 30, 2019 to respond;
4. The last day for the parties to hold the Rule 26 conference is May 30, 2019 — 30 days after the first answer by a defendant;
5. Defendant/Counterclaimant seeks to conduct the conference with the benefit of having had an opportunity to first review Plaintiff/Counter-defendants' response to the counterclaims (due May 30, 2019), and thereby make the conference as efficient as possible;
6. In light of the foregoing, the parties stipulate and agree to extend the time to hold the Rule 26 conference up to, and including, June 4, 2019, and stipulate and agree that the proposed discovery plan and scheduling order shall be filed fourteen days after the Rule 26 conference, i.e., June 18, 2019.
7. This is the first request for the relief sought herein, and it is requested in good faith and not for purposes of delay.
IT IS SO STIPULATED.
DATED this 14th day of May 2019. DATED this 14th day of May 2019.
KRAVITZ, SCHNITZER & JOHNSON, GREENBERG TRAURIG, LLP
CHTD.
/s/Adam Wax /s/ Jason Hicks
MARTIN J. KRAVITZ, ESQ. MARK D. KEMPLE, ESQ.
Nevada Bar No. 83 Admitted Pro Hac Vice
ADAM J. WAX, ESQ. TYLER R. ANDREWS, ESQ.
Nevada Bar No. 12126 Nevada Bar No. 9499
8985 S. Eastern Avenue, Suite 200 JASON K. HICKS, ESQ.
Las Vegas, Nevada 89123 Nevada Bar No. 13149
10845 Griffith Peak Drive, Suite 600
GLASER WEIL FINK HOWARD Las Vegas, Nevada 89135
AVCHEN & SHAPIRO LLP
PATRICIA L. GLASER, ESQ. Attorneys for Defendant/Counterclaimant
Admitted Pro Hac Vice
SEAN RILEY, ESQ.
Admitted Pro Hac Vice
MICHAEL GERST, ESQ.
Admitted Pro Hac Vice
10250 Constellation Blvd., 19th Floor
Los Angeles, CA 90404
Attorneys for Plaintiff/Counter-defendants
ORDER
In consideration of the parties' stipulation, and with good cause appearing, IT IS HEREBY ORDERED that the parties shall hold the Rule 26(f) conference by June 4, 2019.
IT IS FURTHER ORDERED that the stipulated proposed discovery plan and scheduling order is due by June 18, 2019.
