Homesite Insurance Company v. Norcold, Inc. et al, No. 2:2021cv02167 - Document 121 (D. Nev. 2023)
Court Description: ORDER granting 119 Stipulation TO EXTEND DISCOVERY AND OTHER DEADLINES (Fourth Request). Motions due by 5/30/2024. Signed by Magistrate Judge Daniel J. Albregts on 12/20/2023. (Copies have been distributed pursuant to the NEF - CAH)
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Homesite Insurance Company v. Norcold, Inc. et al Doc. 121 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 1 of 14 1 2 3 4 5 6 7 8 9 10 Lilla Shkolnikov (SBN 219484) (admitted pro hac vice) GROTEFELD HOFFMANN LLP 700 Larkspur Landing Circle, Suite 280 Larkspur, California 94939 Telephone: 415.344.9670 Facsimile: 415.989.2802 Email: lshkolnikov@ghlaw-llp.com John T. Keating (Bar No. 6373) KEATING LAW GROUP 9130 W. Russell Rd. Suite 200 Las Vegas, NV 89148 Telephone: 702.228.6800 Email: jkeating@keatinglg.com Attorneys for Plaintiff HOMESITE INSURANCE COMPANY as subrogee of Traci Marx and Raymond Marx 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 14 15 16 17 18 19 20 21 HOMESITE INSURANCE COMPANY as subrogee of Traci Marx and Raymond Marx, Plaintiff, v. NORCOLD, INC., NORCOLD, LLC, THETFORD CORPORATION, THETFORD, LLC, CAMPING WORLD OF HENDERSON, CAMPING WORLD, INC., CWI, Inc. and DOES 1 through 50, Inclusive, Defendants. 22 TRACI MARX, RAY MARX, ALYSSA DILLARD and SETH DILLARD, 23 v. 24 NORCOLD, INC., NORCOLD, LLC, THETFORD CORPORATION, THETFORD LLC, THE DYSON-KISSNER-MORAN CORPORATION, CAMPING WORLD HOLDINGS, INC., CAMPING WORLD, INC., CWI, INC., CAMPING WORLD OF HENDERSON, and DOES 1 to 50, inclusive, and ROE ENTITIES 1 to 50, inclusive 25 26 27 28 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:21-cv-02167-RFB-DJA (Consolidated with Case No. 2:22-cv-00085JCM-EJY) STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER DEADLINES (Fourth Request) 1 Dockets.Justia.com Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 2 of 14 1 Pursuant to LR 6-1 and LR 26-3, the undersigned parties in the consolidated cases, by 2 and through their respective counsel of record, hereby stipulate and respectfully request that this 3 Court further extend certain deadlines contemplated by Scheduling Order currently in place. In 4 support of this Stipulation and Request, the parties state as follows: 5 Procedural History of the Cases 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. On November 5, 2021, Plaintiff Homesite Insurance Company filed its Complaint against Norcold Inc., Thetford Corp., Camping World, Inc. and Camping World of Henderson in the Clark County District Court of the State of Nevada (hereinafter “the Homesite Action”). 2. On December 8, 2021, the Court granted Camping World of Henderson’s and Camping World, Inc.’s Petition for Removal of the Homesite Action to the United States District Court for the District of Nevada. On December 15, 2021, the named defendants in the Homesite Action filed their Answers to the Complaint under Case No. 2:21-cv-02167-RFB-DJA. 3. On December 14, 2021, Plaintiffs Traci Marx, Raymond Marx, Alyssa Dillard and Seth Dillard (“Marx/Dillard Plaintiffs”) filed their Complaint against Norcold, Inc., Thetford Corp., The Dyson-Kissner-Moran Corporation (“DKM”), Camping World Holdings, Inc., Camping World, Inc., CWI, Inc., and Camping World of Henderson (collectively “Camping World Defendants”), in the Clark County District Court of the State of Nevada (hereinafter the “Marx Action”). 4. On January 18, 2022, in the Marx Action, the Court granted Norcold, Thetford, and DKM’s Petition for Removal to the United States District Court for the District of Nevada. Norcold, Thetford, DKM, and the Camping World Defendants filed their Answers to the Complaint in the Marx Action on January 25, 2022 and January 28, 2022 respectively under Case No. 2:22-cv-00085-JCM-EJY. 5. On February 2, 2022, Plaintiffs in the Marx Action filed a Motion to Remand which is currently pending. 6. On February 10, 2022, Plaintiff in the Homesite Action filed a Notice of Related Case regarding the Marx Action. 2 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 3 of 14 1 7. On February 16, 2022, the parties filed their Amended Joint Rule 26(f) Status Report 2 and Discovery Plan in the Homesite Action. Plaintiff and Defendants in the Homesite Action 3 served their Initial Document and Witness Disclosures. 4 5 6 7 8 9 10 11 12 13 14 15 8. On February 24, 2022, Norcold, Thetford, and DKM filed an Amended Proposed Discovery Plan on behalf of the parties in the Marx Action 9. On March 14, 2022, a hearing was held before the Honorable Elayna J. Youchah in the Marx Action regarding the parties’ Amended Proposed Discovery Plan. The Court went through various areas of dispute between the parties, and established the initial scope of discovery in the Marx Action. On May 18, 2022, the Court ordered that the Marx Action, Case No. 2:22-cv00085-JCM-EJY, be consolidated under the Homesite Action, Case No. 2:21-cv02167-RFB-DJA. 10. All parties engaged in written discovery. The parties met and conferred on the terms of a protective order requested by Defendants; however, despite their best efforts, they were unable to agree on the terms of the protective order. Plaintiffs filed a Joint Motion for Protective 16 Order, to which Norcold, Thetford and DKM filed their Response with alternative proposed 17 protective order (such Response being joined by the Camping World Defendants). 18 11. On July 26, 2022, Norcold filed a Motion to Compel Discovery Responses from the 19 Marx/Dillard Plaintiffs in the consolidated action. On July 26, 2022, Norcold also filed a Motion 20 to Deem Requests for Admission Admitted in the Marx Action. 21 22 23 24 25 26 27 28 12. On October 13, 2022, the Court granted Plaintiff Homesite’s motion to amend its Complaint to name CWI, Inc. as a defendant in the Homesite Action. 13. On October 20, 2022, the parties in the consolidated actions submitted a letter requesting a status conference pursuant to Local Rule 16-2. 14. On October 28, 2022, Plaintiff Homesite Insurance Company filed its First Amended Complaint, adding CWI, Inc. as a party. 15. On October 28, 2022, all Defendants filed their answers to the Homesite Plaintiff’s First Amended Complaint. 3 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 4 of 14 1 2 3 16. On November 8, 2022, the parties filed a Joint Stipulation for Extension of Time, which was granted by the Court on November 9, 2022. 17. On December 19, 2022, the Court held a hearing on Norcold’s Motion to Compel 4 Discovery Responses from Plaintiffs and Motion to Deem Requests for Admission Admitted in 5 the Marx Action. The Court ordered that the plaintiffs file an amended complaint naming 6 7 8 9 10 11 12 13 14 15 16 Norcold LLC and Thetford LLC as defendants in the action and that plaintiffs file responses to Norcold LLC’s discovery requests. The Court denied Norcold’s motion to deem requests for admission admitted. 18. On January 17, 2023, Marx/Dillard Plaintiffs filed their First Amended Complaint naming additional Camping World Defendants and Norcold LLC and Thetford LLC as defendants. On January 31, 2023, all Defendants filed their answers to Marx/Dillard Plaintiffs’ First Amended Complaint. 19. On February 8, 2023, and thereafter, Marx/Dillard Plaintiffs filed their responses to Norcold LLC’s discovery requests. 20. On February 28, 2023, Plaintiff Homesite Insurance Company filed its Unopposed 17 Stipulation to File Second Amended Complaint to add Norcold LLC and Thetford LLC as 18 defendants to its action. On March 2, 2023, Plaintiff Homesite Insurance Company’s Second 19 Amended Complaint was deemed filed by the Court. 20 21. On March 2, 2023, Plaintiff Homesite Insurance Company filed a Motion for Leave 21 to File a Third Amended Complaint to add DKM after meet and confer with Defendants Norcold 22 and Thetford where said defendants advised that they opposed Plaintiff’s request to amend the 23 complaint to add DKM as a defendant. 24 25 26 27 28 22. On March 10, 2023, Plaintiff Homesite served an Amended Rule 30(b)(6) Notice of Deposition of Norcold, Inc. (currently known as Norcold LLC.) 23. On March 13, 2023, Plaintiff Homesite Insurance Company and the Marx/Dillard Plaintiffs filed their Joint Motion for Protective Order. 24. On March 16, 2023, Defendants Norcold LLC and Thetford LLC filed their answers 4 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 5 of 14 1 2 to Plaintiff Homesite Insurance Company’s Second Amended Complaint. 25. On March 16, 2023, Defendants Norcold LLC and Thetford LLC filed their response 3 in opposition to Plaintiff Homesite Insurance Company’s Motion for Leave to File its Third 4 Amended Complaint to add DKM. 5 6 7 8 9 10 11 12 13 14 15 16 17 26. On March 20, 2023, Plaintiffs Marx/Dillard and Homesite Insurance Company served joint notices of deposition pursuant to FRCP 30(b)(6) on Norcold, Inc. and on CWI, Inc. 27. On March 21, 2023, named defendants Camping World of Henderson, Camping World, Inc. and CWI, Inc. filed their Joint and Separate Answer and Affirmative Defenses to Plaintiff’s Second Amended Complaint. 28. On or around March 20, 2023, the Marx/Dillard Plaintiffs filed their Notice of Intent to Serve Subpoena on Non-Parties to Testify at Deposition of Christopher Justin Hillenbrand. 29. On March 21, 2023, Plaintiffs Marx/Dillard and Homesite served joint notices of deposition pursuant to FRCP 30(b)(6) on Thetford LLC and DKM. 30. On March 22, 2023, Defendant Norcold served a notice of deposition of Plaintiffs Alyssa Dillard, Seth Dillard, Traci Marx, and Ray Marx. 31. On March 22, 2023, Marx/Dillard Plaintiffs served amended and/or supplemental 18 responses to the Camping World entities’ written discovery requests, including interrogatories, 19 requests for admission and requests for production. 20 21 22 23 24 25 26 27 28 32. On March 23, 2023, Plaintiff Homesite Insurance Company filed its response in reply to Defendants’ opposition to its Motion for Leave to File its Third Amended Complaint. 33. On March 27, 2023, Defendants Norcold LLC, Thetford LLC, and DKM filed their response in opposition to Plaintiffs’ Joint Motion for Protective Order. 34. On March 28, 2023, Defendants Norcold LLC and Thetford LLC filed their Motion to Quash and for a Protective Order Preventing the Apex Deposition of Christopher Justin Hillenbrand. 35. On March 29, 2023, the Court issued a minute order that Defendants’ Motion to Quash and for a Protective Order did not satisfy the meet and confer requirements of the Local 5 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 6 of 14 1 Rules and ordered that the parties meet and confer pursuant to Local Rule IA 1-3(f). 2 36. On March 31, 2023, counsel for Plaintiffs Marx/Dillard and Defendants Norcold and 3 Thetford held a telephonic meet and confer regarding the deposition subpoena of Christopher 4 Justin Hillenbrand. The parties were not able to resolve their discovery dispute. Defendants filed 5 a declaration in support of their Motion to Quash and for Protective Order on March 31, 2023 6 7 8 9 10 11 12 13 pursuant to the Court’s minute order. 37. On April 4, 2023, the Parties filed a second Joint Stipulation to Extend Discovery Deadlines. 38. On April 6, 2023, the Court issued a minute order that the Joint Stipulation to Extend Discovery Deadlines sought to extend a deadline that had already passed (the deadline to amend pleadings or add parties) and did not cite excusable neglect as required under LR 26-3 and ordered the parties to file their stipulation citing excusable neglect on or before April 13, 2023. 39. The Parties filed their Amended Joint Stipulation to Extend Discovery Deadlines, 14 15 removing the deadline to amend pleadings or add parties, on April 6, 2023. The Court granted 16 the Amended Stipulation on April 7, 2023. 40. On April 11, 2023, Marx/Dillard Plaintiffs filed their response to Defendants Norcold 17 18 LLC and Thetford LLCs’ Motion to Quash and for a Protective Order Preventing the Apex 19 Deposition of Christopher Justin Hillenbrand. 20 41. On April 18, 2023, Defendants Norcold LLC and Thetford LLC filed their reply to 21 the Marx/Dillard Plaintiffs’ response to their Motion to Quash and for a Protective Order 22 Preventing the Apex Deposition of Christopher Justin Hillenbrand. 23 24 25 26 27 28 42. On June 15, 2023, the Court issued an order granting Plaintiff Homesite’s Motion for Leave to File Amended Complaint, granting in part and denying in part Plaintiff Homesite’s Joint Motion for Protective Order and granting Defendants Norcold LLC and Thetford LLC’s Motion to Quash and for a Protective Order Preventing the Apex Deposition of Christopher Justin Hillenbrand. The Court ordered the Stipulated Protective Order to be filed by July 14, 2023. 6 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 7 of 14 1 43. On June 21, 2023, Plaintiff Homesite filed its Third Amended Complaint and 2 Demand for Jury Trial, naming The Dyson-Kissner Moran Corporation (“DKM”) as a defendant. 3 44. On July 12, 2023, the Parties filed their Joint Stipulation for Protective Order. 4 45. On July 12, 2023, Defendant DKM filed its Motion to Dismiss Plaintiff Homesite’s 5 Third Amended Complaint. 6 46. On July 18, 2023, the Court granted the Joint Stipulation for Protective Order. 7 8 9 10 11 12 13 14 47. On July 26, 2023, Plaintiff Homesite filed its response to Defendant DKM’s Motion to Dismiss Plaintiff Homesite’s Third Amended Complaint. 48. On July 27, 2023, the Marx/Dillard plaintiffs served notices of deposition for certain current employees and former employees/officers of defendants Norcold, LLC, Thetford, LLC and DKM – Mary Pouliot, John FitzSimons, Heather Ing and Keith Stickley. 49. On August 2, 2023, DKM filed its Reply in Support of Motion to Dismiss Plaintiff Homesite’s Third Amended Complaint Pursuant to FRCP 12(b)(6). 50. On August 7, 2023, Plaintiff Homesite filed the Third Stipulation for Extension of 15 16 Time. 51. On August 9, 2023, the Court granted the Parties’ Third Stipulation for Extension of 17 18 Time. 19 52. On August 31, 2023, the Plaintiffs disclosed their experts and expert reports. 20 53. On September 29, 2023, Homesite and the Marx/Dillard Plaintiffs served the First 21 Amended Joint Notice of Deposition of the Dyson-Kissner-Moran Corporation Pursuant to Fed. 22 R. Civ. P. 30(b)(6), First Amended Joint Notice of Deposition of Thetford, LLC, f/k/a Thetford 23 Corporation Pursuant to Fed. R. Civ. P. 30(b)(6), Second Amended Joint Notice of Deposition of 24 Norcold, LLC, f/k/a Norcold, Inc. Pursuant to Fed. R. Civ. P. 30(b)(6), and Second Amended 25 26 27 28 Joint Notice of Deposition of CWI, Inc. Pursuant to Fed. R. Civ. P. 30(b)(6). 54. On October 2, 2023, the Marx/Dillard Plaintiffs served the First Amended Notice of Deposition of John Fitzsimons, First Amended Notice of Deposition of Keith Stickley, First Amended Notice of Deposition of Heather Ing and First Amended Notice of Deposition of Mary 7 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 8 of 14 1 2 Pouliot. 55. On October 20, 2023, Defendants Thetford LLC and Norcold LLC filed an 3 Emergency Motion for Protective Order regarding the deposition of Mary Pouliot, noticed by the 4 Marx/Dillard Plaintiffs. 5 6 7 8 9 10 11 12 13 14 15 56. On October 20, 2023, the Court issued a minute order denying the emergency nature of the Defendants’ Motion for Protective Order and set a hearing on the Motion for November 29, 2023. 57. On October 23, 2023, Defendant Thetford LLC filed a Motion for Protective Order regarding the deposition of Heather Ing, noticed by the Marx/Dillard Plaintiffs. 58. On October 25, 2023, the Court issued a further minute order that the Motion would also be heard on November 29, 2023. The Court also stayed all discovery until the Court issued its ruling on the pending motions for protective order regarding the depositions of Ms. Pouliot and Ms. Ing. 59. At the November 29, 2023 hearing, the Court granted the Motion for Protective Order 16 regarding the deposition of Mary Pouliot and denied the Motion for Protective Order as to the 17 deposition of Heather Ing. 18 60. On December 13, 2023, the Court issued a Minute Order setting a Hearing on DKM’s 19 Motion to Dismiss Plaintiff Homesite’s Third Amended Complaint for February 6, 2024. [ECF 20 No. 118]. 21 61. The parties have agreed to mediate this matter with the Hon. Trevor Atkin (Ret.) on 22 February 21, 2024. 23 Discovery Remaining 24 25 26 27 28 1. The parties continue participating in written discovery. Specifically, the parties are in the process of meeting and conferring regarding supplemental discovery responses that were served by Defendants following the Court’s entry of the protective order on July 18, 2023. There are at least five (5) separate sets of written discovery at issue between the parties. 8 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 9 of 14 1 2 3 4 5 6 7 8 9 2. The depositions of Plaintiffs Alyssa Dillard and Seth Dillard are currently scheduled to occur on December 21, 2023. 3. The depositions of Plaintiffs Ray Marx and Traci Marx are currently scheduled to occur on January 9, 2024. 4. Resolution of the issues regarding supplemental discovery responses to written discovery described above is a necessary precondition to plaintiffs proceeding with depositions, particularly corporate representative depositions pursuant to FRCP 30(b)(6). As of the date of this application, the parties anticipate potentially taking the following fact depositions: • Nyda Dell Marx; • Rule 30(b)(6) deposition of Homesite • Heather Ing (Thetford, LLC employee); • Keith Stickley (former Norcold, LLC employee); • John FitzSimons (former DKM/Thetford/Norcold officer); 15 • Rule 30(b)(6) depositions of Norcold LLC, Thetford LLC, and DKM; 16 • Rule 30(b)(6) deposition of CWI, Inc., Camping World of Henderson, 10 11 12 13 14 17 18 19 Camping World, Inc. 5. The parties may take the depositions of any and all other witnesses garnered through discovery. 20 6. The parties have disclosed expert witnesses pursuant to Fed. R. Civ. P. 26. 21 7. The parties will take expert depositions. 22 23 24 25 26 27 28 Why Remaining Discovery Has Not Yet Been Completed Good cause exists for the instant request for extension pursuant to Local Rule 26-3. This request for an extension of time is not sought for any improper purpose or for the purpose of delay. Rather, it is sought for the purpose of allowing the parties sufficient time to conduct discovery and adequately prepare for trial. The parties seek additional time as discovery was stayed for over 30 days pending resolution on the Defendants’ motions for protective order regarding the depositions of Mary Pouliot and Heather Ing noticed by Plaintiffs. Furthermore, 9 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 10 of 14 1 the litigation outlined above continues to give rise to complex issues and disputes that the parties 2 are attempting to resolve, including a dispute over the scope of the four Rule 30(b)(6) 3 depositions previously noticed by Plaintiffs. For these reasons, the parties jointly seek court 4 intervention to extend the deadlines as set forth below. 5 6 7 8 9 10 11 12 13 14 In addition, there are motions that remain pending before the Court that are intertwined with the written discovery at issue between the parties, and/or the deposition discovery anticipated by the parties. The motions include the Marx/Dillard plaintiffs’ motion to remand based on lack of diversity jurisdiction related to named Defendant Camping World of Henderson, and DKM’s motion to dismiss Plaintiff Homesite’s Third Amended Complaint, which Plaintiff Homesite opposes. Due to the pending issues and developments outlined above, the parties have not been able to proceed with pre-trial discovery and depositions at the rate they previously anticipated. Accordingly, the parties request a further modification and extension of fact discovery and other 15 trial related deadlines to allow for the opportunity to resolve the above referenced disputes so 16 that discovery and trial preparation can proceed smoothly for the benefit of all parties. 17 Extension of Modification of the Discovery Plan and Scheduling Order Local Rule 26-3 governs modifications or extension of the Discovery Plan and 18 19 Scheduling Order. Any stipulation or motion to extend or modify that Discovery Plan and 20 Scheduling Order must be made no later than twenty-one (21) days before the expiration of the 21 subject deadline and must comply fully with LR 26-3. 22 This is the fourth request for extension of time in this matter. The parties respectfully 23 submit that the reasons set forth above constitute compelling reasons for the extension. 24 The following is a list of the current discovery deadlines and parties’ proposed extended 25 26 27 28 deadlines: /// /// 10 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 11 of 14 1 2 Scheduled Event Fact Discovery Current Deadline Monday January 8, 2024 New Deadline April 15, 2024 3 Expert Discovery Monday, January 8, 2024 May 15, 2024 Tuesday, February 13, 2024 February 29, 2024 6 Mediation Completion Date 7 Dispositive Motions Tuesday, February 13, 2024 May 30, 2024 Joint Pretrial Order To be set pursuant to LR 26-1 (both cases) To be set pursuant to LR 26-1 4 5 8 9 10 11 WHEREFORE, the parties respectfully request that this Court extend fact discovery and other deadlines in accordance with the table above. 12 13 14 Dated: December 18, 2023 15 GROTEFELD HOFFMANN LLP /s/ Lilla Shkolnikov LILLA SHKOLNIKOV Attorneys for Plaintiff Homesite Insurance Company 16 17 18 19 20 21 22 Dated: December 18, 2023 LAW OFFICES OF TERRENCE A. BEARD 23 /s/ Terrence A. Beard 24 TERRENCE A. BEARD, ESQ. (Admitted pro hac vice) California Bar No. 98013 P.O. Box 1599 Sutter Creek, California 95685 T: 925-778-1060 Tbeard1053@aol.com 25 26 27 28 11 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 12 of 14 1 AND 2 DONALD H. WILLIAMS, Esq. Nevada Bar No. 5548 612 So. Tenth Street Las Vegas, Nevada 89101 T: 702-320-7755 F: 702-320-7760 Dwilliams@dhwlawlv.com Attorneys for Plaintiffs Traci Marx, Ray Marx, Alyssa Dillard, and Seth Dillard 3 4 5 6 7 8 9 Dated: December 18, 2023 HINSHAW & CULBERTSON LLP 10 /s/ Russell S. Ponessa Russell S. Ponessa (Admitted Pro Hac Vice) Minnesota Reg. #169316 250 Nicollet Mall, Suite 1150 Minneapolis, MN 55401 11 12 13 14 AND 15 KRAVITZ, SCHNITZER, JOHNSON, & WATSON, CHTD. MARTIN J. KRAVITZ, ESQ. Nevada Bar No. 83 MICHAEL ESPOSITO, ESQ. Nevada Bar No. 13482 8985 S. Eastern Ave., Ste. 200 Las Vegas, NV 89123 Attorneys for Named Defendants CAMPING WORLD OF HENDERSON, CAMPING WORLD, INC. and CWI, Inc. 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: December 18, 2023 COKINOS | YOUNG /s/ Todd M. Foss J. PARKER FAUNTLEROY, JR. Texas Bar No. 00790668 (Pro Hac Vice) TODD M. FOSS Texas Bar No. 24040922 (Pro Hac Vice) MITCHELL R. POWELL Texas Bar No. 24091890 (Pro Hac Vice) 12 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 13 of 14 1 1221 Lamar Street, 16th Floor Houston, Texas 77010 2 AND 3 LEWIS BRISBOIS BISGAARD SMITH LLP DARRELL D. DENNIS, ESQ. Nevada Bar No. 6618 STEVEN B. ABBOTT, ESQ. Nevada Bar No. 10303 MICHAEL R. SMITH, ESQ. Nevada Bar No. 12641 6385 S. Rainbow Blvd., Ste. 600 Las Vegas, Nevada 89118 Attorneys for NORCOLD LLC, THETFORD LLC, and THE DYSON-KISSNER-MORAN CORPORATION 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13 Case 2:21-cv-02167-RFB-DJA Document 119 Filed 12/18/23 Page 14 of 14 1 2 3 4 5 The Court notes that the parties have made substantive changes to the discovery dates, like separating out fact and expert discovery period between the119) close IT IS THEREFORE ORDERED thatand themaking parties' the stipulation (ECF No. No. 19) isis of fact (ECF discovery and the dispositive motions deadline shorter. However, the parties have not ORDER GRANTED. explained why they needed to change these times, rather than simply extending all dates by a IS SOThe ORDERED: certainIT period. Court will require a more robust explanation for changes to the discovery schedule in the future. Nonetheless, the Court finds good cause to grant the parties' instant stipulation. 19th day of _________________, December 2023 Dated this _____ 2024, IT IS THEREFORE ORDERED that the parties' stipulation (ECF No. 119) is GRANTED. 6 7 8 9 10 _____________________________________ DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE UNITED STATES MAGISTRATE JUDGE DATED: December 20, 2023 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14
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