Jiangxi Panda Fireworks Co., LTD v. Burda et al, No. 2:2023cv01232 - Document 51 (D. Nev. 2024)
Court Description: ORDER Granting 50 Motion for Leave to File Excess Pages. Signed by Magistrate Judge Daniel J. Albregts on 2/13/2024. (Copies have been distributed pursuant to the NEF - RJDG)
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Jiangxi Panda Fireworks Co., LTD v. Burda et al Doc. 51 Dockets.Justia.com EXHIBIT 1 EXHIBIT 1 1 2 JODI DONETTA LOWRY, ESQ. Nevada Bar No. 7798 jlowry@gibsonlexbury.com 3 4 5 6 7 Attorneys for Defendants UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 JIANGXI PANDA FIREWORKS CO., LTD, a Chinese entity; 11 12 13 14 15 16 17 Case No.: 2:23-cv-01232-MMD-DJA DECLARATION OF JODI DONETTA LOWRY, ESQ. IN SUPPORT OF DEFENDANT 1.4G HOLDINGS, LLC’S MOTION FOR LEAVE TO EXCEED PAGE LIMITS FOR DEFENDANTS’ MOTION TO COMPEL PLAINTIFF JIANGXI PANDA FIREWORKS CO., LTD’S RESPONSES TO DEFENDANT 1.4G HOLDINGS, LLC’S FIRST SETS OF INTERROGATORIES Plaintiff, v. DOUGLAS BURDA, an individual; KONCEPT LLC, a Nevada limited liability company doing business as BURDA IP; ELISSA BURDA, an individual, RED APPLE FIREWORKS CO., LTD., a Nevada limited liability company; 1.4G HOLDINGS, LLC, a Nevada limited liability company, Defendants. 18 19 DECLARATION OF JODI DONETTA LOWRY, ESQ. 20 21 J.D. Lowry, Esq. states under penalty of perjury of the United States of America that the 22 following is true: 23 1. I am an attorney at Gibson Lexbury LLP, which represents Defendants in the 24 above-captioned matter. I am over eighteen years old and competent to testify to all matters set 25 forth in this Declaration. 26 27 2. It is necessary for Defendant to file a motion that exceeds the page limits provided by LR 7-3 in order to comply with another local rule, LR 26-6(b). 28 1 1 3. Defendant had to set forth the entirety of the interrogatories and Plaintiff Jiangxi 2 Panda Fireworks Co., Ltd.’s (“Plaintiff”) responses as each of Plaintiff’s responses were 3 inadequate. 4 5 6 4. In total, setting forth “in full the text of the discovery originally sought and any response to it” required approximately 16 pages. 5. The scope of the discovery challenged by the Defendants’ Motion to Compel 7 Plaintiff’s Responses to Defendant 1.4g Holdings, LLC’s First Set of Interrogatories (the 8 “Motion to Compel”) required more space, at least 6 more pages, to properly address each of 9 Plaintiff’s discovery deficiencies. 10 Dated this 9th day of February, 2024. /s/ J.D. Lowry Jodi Donetta Lowry, Esq. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2
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