Opinion
2:22-cv-01176-JAD-BNW
10-04-2022
ZACHARY LASKO, an individual, Plaintiff, v. GET FRESH SALES, INC; EMPLOYEES/AGENTS DOES 1-10; and ROE CORPORATIONS 11-20, inclusive, Defendants.
Caitlyn M. Crisp SEYFARTH SHAW LLP Giovanna A. Ferrari (Pro Hac Vice) Caitlyn M. Crisp (Pro Hac Vice) Kaitlin H. Paxton (#13625) KAMER ZUCKER ABBOTT Attorneys for Defendant GET FRESH SALES, INC. JEFFREY GRONICH, ATTORNEY AT LAW, PC. Attorney for -Plaintiff ZACHARY LASKO
Caitlyn M. Crisp SEYFARTH SHAW LLP Giovanna A. Ferrari (Pro Hac Vice) Caitlyn M. Crisp (Pro Hac Vice)
Kaitlin H. Paxton (#13625) KAMER ZUCKER ABBOTT Attorneys for Defendant GET FRESH SALES, INC.
JEFFREY GRONICH, ATTORNEY AT LAW, PC. Attorney for -Plaintiff ZACHARY LASKO
STIPULATION AND REQUEST FOR ADDITIONAL STAY OF DISCOVERY
Second Request
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. Plaintiff and Defendant want 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.
5. Before engaging in formal discovery, the parties agreed to engage in informal discovery, to allow the Parties to value the case appropriately and discuss settlement.
6. The Court granted a stay of discovery of thirty-one days from September 2, 2022 through October 3, 2022.
7. On August 30, 2022, Defendant informally produced documents to Plaintiff.
8. On September 30, 2022, Plaintiff's Counsel Jeffrey Gronich informed Defendant's Counsel that he would need to withdraw from the case and is planning to file a Motion to Withdraw in short order.
9. Plaintiff is currently looking to retain new counsel.
10. As a courtesy to Plaintiff, Defendant has agreed that while Plaintiff's Counsel's forthcoming Motion to Withdraw is pending and Plaintiff is seeing new counsel, another stay in discovery is warranted.
11. The Parties will also be seeking a continuance of the Early Neutral Evaluation (“ENE”) session currently scheduled for October 18, 2022 through a separate stipulation.
12. 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 until one week prior to the rescheduled ENE.
2. The parties agree to file a Joint Discovery Plan and Scheduling Order one week prior to the rescheduled ENE.
3. The parties agree to serve Initial Disclosures one week prior to the rescheduled ENE.