Opinion
2:23-cv-00703
08-02-2023
GEOFF WINKLER, as court-appointed receiver for J&J Consulting Services, Inc., an Alaska corporation; J&J Consulting Services, Inc., a Nevada corporation; and J and J Purchasing LLC, Florida limited liability company, Plaintiff, v. WELLS FARGO BANK, N.A., Defendant.
SEMENZA KIRCHER RICKARD Jarrod L. Rickard, Bar No. 10203 Katie L. Cannata, Bar No. 14848 LEVINE KELLOGG LEHMAN SCHNEIDER + GROSSMAN LLP Jeffrey C. Schneider, Esq Jason K. Kellogg, Esq Marcelo Diaz-Cortes, Esq Attorneys for Plaintiff Joseph G. Went (NBN 9220) Sydney R. Gambee (NBN 14201) HOLLAND & HART LLP K. Issac deVyver (pro hac vice) Alicia A. Baiardo (pro hac vice) Anthony Q. Le (pro hac vice) MCGUIREWOODS Attorneys for Defendant
SEMENZA KIRCHER RICKARD
Jarrod L. Rickard, Bar No. 10203
Katie L. Cannata, Bar No. 14848
LEVINE KELLOGG LEHMAN SCHNEIDER + GROSSMAN LLP
Jeffrey C. Schneider, Esq
Jason K. Kellogg, Esq
Marcelo Diaz-Cortes, Esq
Attorneys for Plaintiff
Joseph G. Went (NBN 9220)
Sydney R. Gambee (NBN 14201)
HOLLAND & HART LLP
K. Issac deVyver (pro hac vice)
Alicia A. Baiardo (pro hac vice)
Anthony Q. Le (pro hac vice)
MCGUIREWOODS
Attorneys for Defendant
STIPULATION FOR EXTENSION OF TIME TO FILE AMENDED DISCOVERY PLAN
HONORABLE NANCY J. KOPPE, UNITED STATES MAGISTRATE JUDGE
Pursuant to Local Rule IA 6-1, the parties hereby stipulate, subject to this Court's approval, to a three-day extension of time to file an amended discovery plan, and state as follows:
WHEREFORE, on July 28, 2023, the Court ordered that the parties file an amended discovery plan by August 2, 2023 [Docket No. 39]. The Court directed the parties to explain the length of the proposed schedule and address the coordination of the schedule in this action with the schedule in the related class action, In re J&J Investment Litigation, No. 2:22-cv-00529-GMN-NJK (D. Nev.);
WHEREAS, the parties respectfully submit that good cause exists to extend the deadline to file an amended discovery plan by three days to address the Court's direction to reconcile the differences between the schedules in this case and the class action. These discussions necessarily involve counsel for the class plaintiffs. In the past 48 hours, the parties have engaged in telephone and e-mail communications on the issue, including communications with class counsel, and have circulated a proposed schedule. The parties believe it will be productive to continue those efforts before filing their amended discovery plan; and
WHEREAS, this is the first motion to extend the time to file an amended discovery plan;
NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between the Parties by and through their counsel, subject to the Court's approval, that the parties file their amended discovery plan and proposed scheduling on or before August 7, 2023.
[PROPOSED] ORDER
IT IS SO ORDERED.