83 Motion to Enlarge Time .pdf

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Original filename: 83 - Motion to Enlarge Time.pdf
Title: Microsoft Word - NV1 Motion for EOT File Discovery Plan
Author: James M Harrington

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Case 2:12-cv-00239-KJD -RJJ Document 83

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Filed 06/19/12 Page 1 of 4

James M. Harrington, pro hac vice
jharrington@harringtonlawpc.com
HARRINGTON LAW, P.C.
P.O. Box 403
Concord, NC 28026-0403
Telephone: 704.315.5800
Facsimile: 704.625.9259
KERRY P. FAUGHNAN, ESQ.
(Nevada Bar No. 12204)
kerry.faughnan@gmail.com
P.O. BOX 335361
North Las Vegas, NV 89033
Telephone: 702.310.3096
Facsimile: 702.331.4222
Attorneys for Plaintiff
SLEP-TONE ENTERTAINMENT CORPORATION

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UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA

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SLEP-TONE ENTERTAINMENT
CORPORATION,

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Plaintiff,
v.
ELLIS ISLAND CASINO &
BREWERY, et al.,

Case No.: 2:12-cv-00239-KJD-RJJ
MOTION FOR EXTENSION OF TIME
TO FILE PROPOSED DISCOVERY
PLAN AND SCHEDULING ORDER
(First Extension Request)

Defendants.

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The Plaintiff, Slep-Tone Entertainment Corporation, by its undersigned

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counsel, hereby moves the Court pursuant to Local Rule 6-1 for an extension of

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time for the parties to file their proposed discovery plan and scheduling order. In

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support of the motion, the Plaintiff shows the Court as follows:

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1.

In a minute order in chambers on June 5, 2012 (Doc. 76), the Court

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noted that the parties had failed to file a proposed Discovery Plan and Scheduling

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Order within the provisions of Local Rule 26-1, and indicated an intention to enter a

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show-cause order if the parties had not complied with Local Rule 26-1 before June
-1MOTION FOR EXTENSION OF TIME TO FILE PROPOSED DISCOVERY PLAN

Case 2:12-cv-00239-KJD -RJJ Document 83

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Filed 06/19/12 Page 2 of 4

19, 2012.
2.

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Although the Plaintiff’s lead counsel at the time the order was entered,

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Donna Boris, apparently commenced discussions with counsel of record for the

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Defendants, the Plaintiff terminated Ms. Boris as its attorney before those

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discussions were completed.1
3.

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The Plaintiff’s new undersigned counsel, James M. Harrington, re-

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initiated discussions with the Defendants’ counsel of record on June 18 following

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his admission pro hac vice, but he has been unable to speak directly with any of the

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counsel of record and has not received from Ms. Boris any information about her

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discussions with the Defendants’ counsel.
4.

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In the view of the Plaintiff’s new counsel, the failure to file a proposed

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Discovery Plan and Scheduling Order is principally an issue of logistics and a short

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timetable, not of deep-seated disagreement, and that the parties will be able to come

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quickly to an agreement on a plan in short order. The Plaintiff is agreeable with the

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dates and other provisions in the proposed order (Doc. 79) filed unilaterally with

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the Court by Café Moda and other Defendants on June 13, 2012.
5.

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It is respectfully submitted that good cause exists for a two-week

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extension of time, to July 3, 2012, for the parties to file their proposed Discovery

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Plan and Scheduling Order.

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///

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///

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///

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Slep-Tone will be filing a stipulation for substitution of counsel as soon as the papers can be completed.

-2MOTION FOR EXTENSION OF TIME TO FILE PROPOSED DISCOVERY PLAN

Case 2:12-cv-00239-KJD -RJJ Document 83

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Filed 06/19/12 Page 3 of 4

Respectfully submitted this the 19th day of June, 2012.
HARRINGTON LAW, P.C.

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BY:

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/s/
JAMES M. HARRINGTON
(pro hac vice) (N.C. Bar No. 30005)
P.O. Box 403
Concord, NC 28026-0403
(704) 315-5800
AND

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KERRY P. FAUGHNAN, ESQ.
(Nevada Bar No. 12204)
kerry.faughnan@gmail.com
P.O. BOX 335361
North Las Vegas, NV 89033
Telephone: 702.310.3096
Facsimile: 702.331.4222

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Attorneys for Plaintiff
SLEP-TONE ENTERTAINMENT
CORPORATION

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IT IS SO ORDERED that the time for the parties to file to file their proposed

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Discovery Plan and Scheduling Order is hereby extended up to and including July

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3, 2012.

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DATED this __ of June, 2012.
________________________________________

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UNITED STATES DISTRICT JUDGE

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-3MOTION FOR EXTENSION OF TIME TO FILE PROPOSED DISCOVERY PLAN

Case 2:12-cv-00239-KJD -RJJ Document 83

Filed 06/19/12 Page 4 of 4

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CERTIFICATE OF SERVICE

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The undersigned hereby certifies that the foregoing paper is being filed using
the Clerk’s CM/ECF system, which will send a Notice of Electronic Filing to
counsel of record as follows:

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Frank A Ellis - fellis@lvbusinesslaw.com
John M. Sacco - jsacco@marquisaurbach.com
Lauri S. Thompson - thompsonl@gtlaw.com
Mark G Tratos - tratosm@gtlaw.com
Tamara Beatty Peterson - TPeterson@bhfs.com
Terry A. Coffing - tcoffing@marquisaurbach.com
Peter H. Ajemian - AjemianP@gtlaw.com
Kendelee Leascher-Works - kworks@weidemiller.com
Brian R. Hardy - bhardy@marquisaurbach.com
Jonathan W Fountain - jfountain@lrlaw.com
Ryan R Gile - rgile@weidemiller.com
Laura Bielinski - lbielinski@bhfs.com
Nikkya G. Williams - nwilliams@lrlaw.com
Thomas D Boley - tboley@boleylawgroup.com
Robert Beyer - rbeyer@siegelcompanies.com
Joseph Bistritz - jbistritz@siegelcompanies.com
CM/ECF non-participants are being served on the date indicated below by
depositing a copy of this paper as First Class Mail, postage prepaid, addressed as
follows:
Tara King
1904 Chavez Ct.
N. Las Vegas, NV 89031

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Date: June 19, 2012

/s/
James M. Harrington

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-4CERTIFICATE OF SERVICE


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