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Dixon v. Legacy Transportation Systems, LLC

United States District Court, D. Nevada

April 21, 2017

SARAH DIXON, Plaintiff,
v.
LEGACY TRANSPORTATION SYSTEMS, LLC, ; a Utah Limited Liability Company; ANGELES TRANSPORTATION, LLC; a Utah Limited Liability Company, LEONCIO ANGELES; Defendants. LEGACY TRANSPORTATION SYSTEMS, LLC; ANGELES TRANSPORTATION, LLC; AND LEONCIO ANGELES, Third-Party Plaintiffs,
v.
RYAN RICHARDS, Third-Party Defendant.

          HALL JAFFE & CLAYTON, LLP STEVEN T. JAFFE JASON R. WIGG, ESQ. Attorneys for Defendants/Third-Party Plaintiff Legacy Transportation Systems, LLC, Angeles Transportation, LLC & Leoncio Angeles

          MCCULLOUGH, PEREZ & DOBBERSTEIN LTD.CHRISTOPHER McCULLOUGH, ESQ. Attorneys for Plaintiff

          RANALLI ZANIEL FOWLER & MORAN, LLC BENJAMIN J. CARMAN, ESQ. Attorneys for Third-Party Defendant, Ryan Richards

          STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO COMPLETE DISCOVERY

         Defendant Ryan Richards (“Richards”), by and through their respective counsel of record, hereby stipulate and agree to extend discovery for 14 days only the limited purpose of completing four specific depositions only that, due to scheduling issues and the need to travel to Utah, could not be completed before the end of the current discovery cut-off date.

         I. Discovery Completed to Date

         The Parties have been diligently conducting discovery efforts as follows:

         1. The parties have exchanged initial documents and witness lists;

         2. The parties have conducted written discovery and responded to those requests;

         3. Plaintiff has served Multiple Supplemental Document/Witness Disclosures;

         4. The Legacy Defendants have served Multiple Supplemental Document/Witness Disclosures;

         5. Richards has served Supplemental Document/Witness Disclosures;

         6. Plaintiff has disclosed and served reports from the following experts:

a. Chris P. Reyes, MRC, CRC;
b. Joseph T. Crouse, Ph.D., MBA, CPA;
c. Kathleen Smith, MD
d. Brian K. Jones, MSBI, P.E. ACTAR, CXLT

         7. The Legacy Defendants have disclosed and served reports from ...


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