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Zapinski v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

November 13, 2017

MICHELLE ZAPINSKI, an individual; Plaintiffs,
v.
WAL-MART STORES, INC., a foreign corporation d/b/a WAL-MART SUPERCENTER #1584; DOES 1 through 10, inclusive; ROE CORPORATIONS 11 through 20, inclusive; and ABC LIMITED LIABILITY COMPANIES 21 through 30, inclusive, Defendants.

          BRIAN 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)

         COME 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.

         I. Local Rule 6-1

         Under 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.

         a. The Requirement of Local Rule 6-1 Are Satisfied

         This is 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 time allotted.

         II. Local Rule 26-4(a)

         Under LR 26-4(a) a statement specifying the Discovery completed:

         a. Initial disclosures have been exchanged between all parties.

         b. Written discovery has been expedited.

         III. Local Rule 26-4(b)

         Under 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 19, 2017.

         IV. Local ...


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