United States District Court, D. Nevada
D. NETTLES, ESQ. Nevada Bar No. 7462 WILLIAM R. KILLIP, JR.
Nevada Bar No. 3660 JENNIFER PETERSON, ESQ. Nevada Bar No.
11242 NETTLES LAW FIRM Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE
DATES (FIRST REQUEST)
NOW, Plaintiff MICHELLE ZAPINSKI, by and through her
attorneys BRIAN D. NETTLES, ESQ., and WILLIAM R. KILLIP, JR.,
ESQ., and JENNIFER A. PETERSON, ESQ., of the NETTLES LAW
FIRM; and Defendant WAL-MART STORES, INC. d/b/a WAL-MART
SUPERCENTER #1584, by and through their attorneys ROBERT K.
PHILLIPS, ESQ., and RYAN KERBOW, ESQ., of PHILLIPS, SPALLAS
& ANGSTADT, LLC, and hereby submit the following
Stipulation pursuant to Local Rule 26-4. Based upon the
following, the Parties request this Court extend all
discovery deadlines by sixty (60) days. This request is made
in good faith and not to unduly delay the proceedings.
Local Rule 6-1
LR 6-1(b) every stipulation to extend time must inform the
court of any previous extensions granted and state the reason
for the extension requested.
The Requirement of Local Rule 6-1 Are
the first request for extension filed by the parties. The
parties are seeking this extension in order to complete
additional discovery that could not be completed during the
Local Rule 26-4(a)
LR 26-4(a) a statement specifying the Discovery completed:
Initial disclosures have been exchanged between all parties.
Written discovery has been expedited.
Local Rule 26-4(b)
LR 26-4(b) a specific description of the Discovery that
remains to be completed:
a. The remaining Discovery to be completed is Plaintiff's
deposition, FRCP 30(b)(6) depositions of Defendant,
Deposition of Defendant's employees, depositions of
treating physicians, and disclosure and depositions of the
experts. Of note: the deposition of Plaintiff is currently
scheduled to take place on November 29, 2017 and the
deposition of Dr. Yavgeniy Khavkin, Plaintiff's treating
physician, is currently scheduled to take place on December