Bass Underwriters, Inc. v. Kono

Full title: Bass Underwriters, Inc., Plaintiff v. David Kono, Defendant.

Court: United States District Court, District of Nevada

Date published: Feb 8, 2023

2:22-cv-00138-RFB-EJY (D. Nev. Feb. 8, 2023)

Opinion

2:22-cv-00138-RFB-EJY

02-08-2023

Bass Underwriters, Inc., Plaintiff v. David Kono, Defendant.

COZEN O'CONNOR Karl O. Riley (Nevada Bar No. 12077) BROWNSTEIN HYATT FARBER SCHRECK, LLP Travis F. Chance (Nevada Bar No. 13800)

RICHARD E. BOULWARE, II., UNITED STATES DISTRICT COURT.

COZEN O'CONNOR

Karl O. Riley (Nevada Bar No. 12077)

BROWNSTEIN HYATT FARBER SCHRECK, LLP

Travis F. Chance (Nevada Bar No. 13800)

STIPULATION AND ORDER TO CONTINUE THE DISPOSITIVE MOTIONS DEADLINE

(FIRST REQUEST)

RICHARD E. BOULWARE, II., UNITED STATES DISTRICT COURT.

Plaintiff Bass Underwriters, Inc. (“Bass”) and Defendant David Kono (“Kono”) stipulate for a (first request) continuation of the dispositive motions deadline, and in support whereof aver as follows:

1. On January 6, 2023, Bass moved on an emergency basis for leave to file an amended complaint to assert claims against Brooks, and to continue the discovery period. ECF No. 35. Kono filed his response on January 20, 2023 (ECF No. 37), and Bass filed a reply in support of its motion on January 31, 2023 (ECF No. 47). The Court issued an Order, denying the emergency status of the motion (ECF No. 36). This motion is currently pending before the Court.

2. On January 24, 2023, Kono moved, on an emergency basis, for a protective order precluding the deposition of Kono's employer, Brooks Group Insurance Agency, LLC's (“Brooks”) corporate representative (ECF No. 39). Bass filed its response in opposition to this motion on February 6, 2023 (ECF No. 49), and Kono is scheduled to reply on February 13, 2023. The Court issued an Order, addressing the emergency request of the motion by staying Brooks' deposition until the motion is ruled upon (ECF No. 40). This motion is currently pending before the Court, and, as such, the deposition has not yet occurred.

3. While these motions remain pending, the March 1, 2023 deadline established in the existing Scheduling Order for filing dispositive motions remains in force (ECF No. 32).

4. The parties have conferred and, due to the several motions pending before the Court, for judicial efficiency, and the economy of the parties, the parties agree to a continuation of the dispositive motions deadline to March 15, 2023.

5. This stipulation is for good cause and not for purposes of delay.

IT IS SO STIPULATED.

ORDER

For good cause appearing, IT IS SO ORDERED.