Nevada Power Company v. Trench France SAS, 2:15-cv-00264

Nevada Power Company sued Trench France SAS (among others); Trench moved to dismiss for lack of personal jurisdiction.
Trench moved to stay discovery pending resolution of its motion to dismiss.
Plaintiff opposed, arguing jurisdictional discovery and citing contacts: ~800 Trench bushings in Nevada, a sales division targeting Nevada, Trench’s contact to arrange an inspection in Nevada, and written acknowledgment of an ongoing business relationship with Nevada Power.
The magistrate judge considered whether to stay discovery under the district’s standard balancing Rule 1 goals and precedent permitting stays where a potentially dispositive motion is pending.
The court took a limited “preliminary peek” at the motion to dismiss but was not convinced personal jurisdiction would be found by the district judge.
The court granted the stay of discovery as to Trench France SAS, deferring any decision about jurisdictional discovery to the assigned district judge resolving the motion to dismiss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether discovery should be stayed pending a potentially dispositive motion to dismiss raising personal jurisdiction	Discovery (including jurisdictional discovery) should proceed because factual record insufficient and plaintiff alleges multiple Nevada contacts	Discovery should be stayed because the motion to dismiss is potentially dispositive and can be resolved without discovery; jurisdictional challenge is a critical preliminary issue	Stay granted as to Trench France SAS; jurisdictional discovery question deferred to the district judge

Tradebay, LLC v. eBay, Inc., 278 F.R.D. 597 (D. Nev. 2011) (district court may deny blanket discovery stays; courts must balance Rule 1 goals when considering stays)
Kor Media Group, LLC v. Green, 294 F.R.D. 579 (D. Nev. 2013) (courts may stay discovery where motion is potentially dispositive, can be decided without discovery, and a preliminary peek suggests plaintiff cannot state a claim)