Opinion
3:22-cv-05718-TMC
10-27-2023
RYAN RANER, an individual, Plaintiff, v. THE FUN PIMPS ENTERTAINMENT, LLC, a Texas limited liability company; RICHARD HUENINK, JR., an individual; and JOEL HUENINK, an individual, Defendants. THE FUN PIMPS ENTERTAINMENT, LLC, a Texas limited liability company, Counterclaim Plaintiff, v. RYAN RANER, an individual, Counterclaim Defendant.
Ashley J. McDonald, WSBA No. 58237 Venkat Balasubramani, WSBA No. 28269 FOCAL PLLC Attorneys for Ryan Raner David A. Lowe, WSBA No. 24453 LOWE GRAHAM JONES PLLC J. Pat Heptig (admitted pro hac vice) HEPTIG LAW GROUP, LTD. Attorneys for Defendant
NOTE ON MOTION CALENDAR: October 26, 2023
Ashley J. McDonald, WSBA No. 58237
Venkat Balasubramani, WSBA No. 28269
FOCAL PLLC
Attorneys for Ryan Raner
David A. Lowe, WSBA No. 24453
LOWE GRAHAM JONES PLLCJ. Pat Heptig (admitted pro hac vice)
HEPTIG LAW GROUP, LTD.
Attorneys for Defendant
STIPULATED MOTION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DATES
TIFFANY M. CARTWRIGHT, UNITED STATES DISTRICT COURT JUDGE
STIPULATION
The parties jointly stipulate and respectfully move the Court for an order extending all discovery dates as set forth herein. The extension of the discovery dates as requested herein will not impact the trial or related dates. The parties believe that good cause is shown for this extension for at least the following reasons:
• The current initial expert disclosure deadline is November 13, 2023, and rebuttal
expert disclosures due on December 13, 2023.
• Plaintiff has requested, and Defendant has agreed, to extend the initial expert disclosure and rebuttal expert disclosure deadlines.
• Along with the extended expert disclosure deadlines, both parties agree that additional time is needed to complete discovery in light of both witness and counsel professional and personal commitments, extending the close of discovery by one month, from January 22nd to February 23rd.
• The parties also request that the dispositive motion deadline be extended by two weeks, from February 21st to March 7th to allow the completion of discovery prior to the deadline for dispositive motions.
• The requested extensions do not impact the current trial setting or any trial-related deadlines.
The proposed new schedule is as follows:
Action
Current Date
Proposed Date
5 DAY JURY TRIAL set for 09:00 AM
May 21, 2024
No change
Disclosure of expert testimony under FRCP 26(a)(2)
Nov 13, 2023
Dec 4, 2023
Disclosure of rebuttal expert testimony under FRCP 26(a)(2)
Dec 13, 2023
Jan 15, 2024
All motions related to discovery must be filed by
Dec 26, 2023
Jan 26, 2024
Discovery completed by
Jan 22, 2024
Feb 23, 2024
All dispositive motions must be filed by
Feb 21, 2024
Mar 7, 2024
Motions in limine should be filed pursuant to Local Rule CR 7(d)(4) by
Apr 15, 2024
No change
Agreed pretrial order filed with the Court by
Apr 29, 2024
No change
Trial briefs, proposed voir dire, jury instructions, agreed neutral statement of the case and deposition designations due by
Apr 30, 2024
No change
Pretrial conference will be held at 03:00 PM on
May 6, 2024
No change
The stipulated extension is not submitted for the purposes of delay, but rather due to litigation and party logistics, and is in the interest of justice and fairness. The parties respectfully request that the Court agree to the stipulated extension of time and issue the proposed order submitted herewith.
I certify that this memorandum contains 388 words, in compliance with the Local Civil Rules.
ORDER
Pursuant to the Stipulation of the parties, IT IS SO ORDERED.