United States District Court, D. Nevada
D. NETTLES, ESQ., CHRISTIAN M. MORRIS, EDWARD J. WYNDER, ESQ.
NETTLES LAW FIRM Attorneys for Plaintiff
TIMOTHY D. KUHLS, ESQ.Attorneys for Defendant
STIPULATION TO EXTEND DISCOVERY DEADLINES (FIRST
Robert Flores (“Plaintiff”), by and through his
counsels of record, Brian D. Nettles, Esq. Christian M.
Morris, Esq., and Edward J. Wynder, Esq., of Nettles Law
Firm, and Defendant, Wal-Mart Stores, Inc. d/b/a Wal-Mart
Neighborhood Market #3355 (“Defendant”), by and
through its counsel of record, Timothy D. Kuhls, Esq., Esq.,
of Phillips, Spallas & Angstadt, LLC, hereby stipulate to
the extension of all remaining discovery deadlines by
sixty (60) days pursuant to LR 26-4.
the parties have begun discovery but still have substantial
discovery to complete before they will be ready for trial,
the parties request a sixty (60) day extension of certain
discovery deadlines as set forth below.
DISCOVERY COMPLETED TO DATE
parties participated in the Fed. R. Civ. P 26(f) conference
on August 15, 2017.
Plaintiff made his pre-discovery disclosures pursuant to Fed.
R. Civ. P 26.1(a)(1) on August 28, 2017. Defendant served its
pre-discovery disclosures pursuant to Fed.R.Civ.P. 26.1(a)(1)
on September 15, 2017.
Defendant propounded written discovery to Plaintiff on
September 18, 2017 and Plaintiff responded to Requests for
Admissions on October 11, 2017 and Requests for Production of
Documents on October 16, 2017 and Interrogatories on October
Plaintiff propounded written discovery to Defendant on
November 1, 2017.
SPECIFIC DESCRIPTION OF THE DISCOVERY TO BE
has been unable to designate a medical expert or produce a
report due to scheduling conflicts of the expert.
Defendant's responses to Plaintiff's written
discovery is due December 1, 2017. The parties have conducted
one deposition of Defendant's girlfriend, the deposition
of one of Defendant's employees is currently scheduled.
The parties intend to depose several individuals including
Plaintiff, Defendant's Rule 30(b)(6) designee(s),
treating medical professionals, expert witnesses and other
employees of Defendant.
REASONS FOR EXTENSION TO COMPLETE DISCOVERY
the good faith efforts of the parties to comply with the
Court's discovery deadlines, various scheduling conflicts
have occurred. As set forth above, Plaintiff has experienced
a delay in producing a medical expert report due to the
scheduling conflicts of the medical expert. Accordingly, the
parties believe a sixty (60) day extension to ...