Opinion
2:19-cv-00226-GMN-VCF
10-26-2023
AMY BUCHANAN Plaintiff, v. WATKINS & LETOFSKY, LLP., a Nevada Limited Liability Partnership; and DOES 1-X, inclusive, Defendants.
WATKINS & LETOFSKY, LLP Daniel R. Watkins, Esq. Nevada State Bar No. 11881 Brian S. Letofsky, Esq. Nevada State Bar No. 11836 Attorneys for Watkins & Letofsky, LLP KEMP & KEMP J.P. Kemp, Esq. Attorney for Amy Buchanan
WATKINS & LETOFSKY, LLP
Daniel R. Watkins, Esq. Nevada State Bar No. 11881
Brian S. Letofsky, Esq. Nevada State Bar No. 11836
Attorneys for Watkins & Letofsky, LLP
KEMP & KEMP
J.P. Kemp, Esq.
Attorney for Amy Buchanan
STIPULATION AND ORDER TO EXTEND DEADLINE FOR FILING MOTIONS FOR SUMMARY JUDGMENT
Pursuant to this court's order on Defendant's Motion for Summary Judgment (ECF No. 55), the Stipulated Discovery Plan and Scheduling Order (ECF No. 58) and Federal Rule of Civil Procedure 26(f), and in accordance with LR IA 6-1, Defendant, Watkins & Letofsky, LLP, and Plaintiff, Amy Buchanan, by and through their respective counsel, stipulate and hereby submit to the Court this joint request for a 30 day extension of the deadline for filing dispositive motions as contained in the Stipulated Discovery Plan and Scheduling Order (ECF No. 58) from October 30, 2023 through and including November 29, 2023 The Parties represent and show the court as follows:
1. The discovery cut-off date from the Stipulated Discovery Plan and Scheduling Order (ECF No. 58) was originally set for September 29, 2023, and the dispositive motion filing deadline was set for 30 days later on October 30, 2023 (the 29th being a Sunday).
2. The Court granted Plaintiff an extension of time to complete the necessary depositions to October 9, 2023, as travel plans for the witnesses made it difficult to schedule the in-person depositions (ECF No. 61).
3. Counsel for Defendant, Daniel Watkins, underwent significant shoulder surgery on October 6, 2023, limiting his time in the office for several weeks.
4. The parties completed the necessary depositions on October 9, 2023.
5. With the limited time in the office and the time needed to obtain the deposition transcripts, the parties request a 30-day extension of the dispositive motion filing deadline making the new deadline November 29, 2023. This first joint request for an extension of time of the deadline to file dispositive motions.
Good cause exists for the proposed extension of the deadline for filing dispositive motions, and the parties believe that an extension is necessary. Based on the foregoing, the parties have agreed that the deadline for filing dispositive motions should be extended until Wednesday November 29, 2023.
ORDER
IT IS SO ORDERED.