Opinion
2:22-cv-01176-JAD-BNW
08-29-2022
ZACHARY LASKO, an individual, Plaintiff, v. GET FRESH SALES, INC; EMPLOYEES/AGENTS DOES 1-10; and ROE CORPORATIONS 11-20, inclusive, Defendants.
SEYFARTH SHAW LLP Giovanna A. Ferrari (Pro Hac Vice) Caitlyn M. Crisp (Pro Hac Vice) KAMER ZUCKER ABBOTT Attorneys for Defendant GET FRESH SALES, INC. JEFFREY GRONICH, ATTORNEY AT LAW, P.C. Attorney for Plaintiff ZACHARY LASKO
SEYFARTH SHAW LLP Giovanna A. Ferrari (Pro Hac Vice) Caitlyn M. Crisp (Pro Hac Vice) KAMER ZUCKER ABBOTT Attorneys for Defendant GET FRESH SALES, INC.
JEFFREY GRONICH, ATTORNEY AT LAW, P.C. Attorney for Plaintiff ZACHARY LASKO
STIPULATION AND REQUEST FOR STAY OF DISCOVERY OF THIRTY-ONE (31) DAYS First Request
The Hon. Brenda Weksler United States Magistrate Judge
A. Facts Relevant to Stay Requested
1. Plaintiff filed the Complaint on June 12, 2022.
2. Defendant removed the case to federal court on July 21, 2022 3. Defendant answered the Complaint on July 28, 2022.
4. On September 9, 2022, the parties are due to file the proposed Discovery Plan and Scheduling Order.
5. Plaintiff and Defendant would like to devote their resources to an early resolution of this case and want to minimize to the extent possible the expenditure of monies for attorneys' fees.
6. Before engaging in formal discovery, the parties have agreed to engage in informal discovery, which will allow the Parties to value the case appropriately.
7. Following the informal productions, the parties intend to discuss possible resolution of this case.
8. The parties agree that the documents requested by Plaintiff and Defendant for the informal discovery will be produced by close of business on September 2, 2022.
9. In order to have time to perform the above without engaging in the expense of formal discovery, the parties agree a stay of discovery is in order.
10. This Stipulation is made for the purposes stated above and not for purposes of delay or any other improper purpose.
B. Stay of Discovery .
1. The parties agree to stay discovery in this matter for thirty-one days from September 2, 2022, which is until October 3, 2022.
2. Defendant will produce Plaintiff's personnel file by September 2, 2022.
3. Plaintiff will produce documents and information regarding his subsequent employment following his termination of employment by Defendant, including his efforts to obtain subsequent employment and his earnings to date by September 2, 2022.
4. If the parties do not have an agreement to settle by September 27, 2022, the parties will file a Discovery Plan and Scheduling Order no later than October 4, 2022.
ORDER
For the reasons stated above, and for good cause, it is hereby ordered as follows:
1. Defendant will produce Plaintiff's personnel file by September 2, 2022.
2. Plaintiff will produce documents and information regarding his subsequent employment following his termination of employment by Defendant, including his efforts to obtain subsequent employment and his earnings to date by close of business on September 2, 2022.
3. The parties agree to stay discovery in this matter for thirty-one days from September 2, 2022, which is until October 3, 2022.
4. The parties will file a proposed Discovery Plan and Scheduling Order by 10/4/2022.
IT IS SO ORDERED.