Opinion
2:22-cv-00138-RFB-EJY
04-21-2023
BASS UNDERWRITERS, INC., Plaintiff, v. DAVID KONO, Defendant.
ZUMPANO PATRICIOS POPOK HELSTEN, PLLC MICHAEL S. POPOK, ESQ. Pro Hac Vice Application Forthcoming (Admitted Pro Hac Vice) AMANDA J. BROOKHYSER, ESQ. Nevada Bar No. 11526 Counsel for Defendant, DAVID KONO COZEN O'CONNOR POPOK & HELSTEN, PLLC KARL O. Riley, Esq. Nevada Bar No. 12077 Counsel for Defendant Counsel for Plaintiff Bass Underwriters, Inc.
ZUMPANO PATRICIOS POPOK HELSTEN, PLLC
MICHAEL S. POPOK, ESQ.
Pro Hac Vice Application Forthcoming
(Admitted Pro Hac Vice)
AMANDA J. BROOKHYSER, ESQ.
Nevada Bar No. 11526
Counsel for Defendant,
DAVID KONO
COZEN O'CONNOR
POPOK & HELSTEN, PLLC
KARL O. Riley, Esq.
Nevada Bar No. 12077
Counsel for Defendant Counsel for Plaintiff
Bass Underwriters, Inc.
STIPULATION AND ORDER TO EXTEND THE DISPOSITIVE MOTIONS DEADLINE
(FOURTH REQUEST)
ELAYNA J. YOUCHAH UNITED STATES MAGISTRATE JUDGE
Defendant David Kono (“Kono”) and Plaintiff Bass Underwriters, Inc. (“Bass”) stipulate for a continuation, the parties' fourth request of the dispositive motions deadline, and in support of 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). 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 replied 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 May 15, 2023 deadline for filing dispositive motions remains in force (ECF No. 54).
4. On April 19, 2023, Kono filed a Stipulation and Order of Substitution of Counsel (ECF No. 57). The Stipulation and Order of Substitution of Counsel is currently pending with the Court.
5. The parties have conferred and, due to the several motions pending before the Court, and newly substituted counsel now representing Defendant Kono, the parties have agreed to a continuation of the dispositive motions deadline to July 175, 2023.
6. This stipulation is for good cause, and is not for the purposes of delay or prejudice to any party, but in light of newly substituted counsel.
ORDER
IT IS SO ORDERED.