Opinion
2:19-cv-01757-GMN-EJY
08-14-2023
THOMAS K. KURIAN, individually, Plaintiff/Counterdefendant, v. SNAPS HOLDING COMPANY, a North Dakota Domestic Corporation, Defendant/Counterclaimant.
MESSERLI & KRAMER, PA By: Brendan R. Tupa BRENDAN R. TUPA, ESQ. Nevada Bar No Pro Hac Vice KAEMPFER CROWELL RICHARD G. CAMPBELL, JR., ESQ. Attorneys for Defendant/ Counterclaimant SNAPS Holding Company E BRENT BRYSON, LTD. By: E. Brent Bryson E. BRENT BRYSON, ESQ. Attorneys for Plaintiff/ Counterdefendant Thomas K. Kurian
MESSERLI & KRAMER, PA
By: Brendan R. Tupa
BRENDAN R. TUPA, ESQ.
Nevada Bar No Pro Hac Vice
KAEMPFER CROWELL
RICHARD G. CAMPBELL, JR., ESQ.
Attorneys for Defendant/ Counterclaimant SNAPS Holding Company
E BRENT BRYSON, LTD.
By: E. Brent Bryson
E. BRENT BRYSON, ESQ.
Attorneys for Plaintiff/ Counterdefendant Thomas K. Kurian
UNOPPOSED MOTION/STIPULATION TO EXTEND DISCOVERY DEADLINE AND DEADLINE TO FILE JOINT PRETRIAL ORDER [FIRST REQUEST TO EXTEND DISCOVERY DEADLINE; FOURTH REQUEST TO EXTEND DEADLINE TO FILE JOINT PRETRIAL ORDER]
HONORABLE ELAYNA J. YOUCHAH UNITED STATES MAGISTRATE JUDGE
Pursuant to LR IA 6-1(a), Defendant and Counterclaimant SNAPS Holding Company (“SNAPS”) respectfully submits this Memorandum of Points and Authorities in Support of its Unopposed Motion/Stipulation to Extend Discovery Deadline and Deadline to File Joint Pretrial Order. SNAPS' counsel has conferred with Mr. Kurian's counsel, and Mr. Kurian's counsel has no objection to this motion.
POINTS AND AUTHORITIES
In the Court's Order of June 21, 2023, it reopened discovery for 60 days to allow, among other things, SNAPS to depose PTC-220, LLC and redepose Mr. Kurian. (See ECF 102). The discovery period ends on August 21, 2023.
Since the Court's Order, the parties have deposed PTC-220, LLC and were coordinating the deposition of Mr. Kurian. Unfortunately, SNAPS' counsel, Mr. Tupa, recently suffered a serious, unforeseen medical issue. Mr. Tupa requires additional time to recover, and the parties are unable to complete discovery by August 21, 2023. SNAPS has conferred with Mr. Kurian's counsel, and the parties agree that a 60-day extension of the discovery deadline will allow Mr. Tupa time to recover and continue forward with this matter. SNAPS, therefore, respectfully requests that the Court extend the discovery deadline from August 21, 2023 to October 20, 2023.
Additionally, because the parties' Joint Pretrial Order is due 30 days from the end of discovery (currently set for September 21, 2023), SNAPS respectfully requests that the Court extend the Joint Pretrial Order deadline to November 20, 2023.
Respectfully submitted.
ORDER
IT IS SO ORDERED.