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Hernandez v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

November 17, 2017

EDDIE HERNANDEZ, Plaintiff,
v.
WAL-MART STORES, INC. d/b/a WALMART SUPERCENTER #3473; SECURITAS SECURITY SERVICES USA, INC.; UNKNOWN SECURITY GUARD; DOES 1-V, inclusive; ROE BUSINESS ENTITIES I-V, inclusive, Defendants.

          SPRINGEL & FINK LLP LEONARD T. FINK, ESQ. Nevada Bar No. 6296 NAKESHA S. DUNCAN, ESQ. Nevada Bar No. 11556

          GAZDA & TADAYON LEWIS GAZDA, ESQ. Nevada Bar No. 4269 AFSHIN TADAYON, ESQ. Nevada Bar No. 6517

          STIPULATION TO EXTEND DISCOVERY

         The parties, by and through their respective, undersigned, attorneys of record, hereby submits this Stipulation and Order to Extend Discovery Deadlines, as detailed below.

         Pursuant to LR IA 6-1, this is the third stipulation for extension of time for discovery submitted by the parties. Pursuant to LR II 26-4, the parties agree to extend the remaining discovery deadlines to allow each party to complete the remaining, necessary discovery. As the parties wish to conduct mediation, good cause exists to allow the parties additional time to conduct the remaining discovery, including depositions.

         A. Discovery Completed

         The following discovery has been completed:

1. Plaintiff and Defendants have exchanged FRCP 26 disclosures of witnesses and documents, and supplements thereto.
2. Defendant SECURITAS SECURITY SERVICES USA, INC. has propounded written discovery upon Plaintiff.
3. Plaintiff has propounded written discovery upon Defendants.
4. Defendants have responded to Plaintiff's written discovery.
5. Plaintiff has responses to Defendants' written discovery.
6. An independent medical examination of Plaintiff has been completed.
7. Defendants have disclosed their initial expert witness.

         B. Discovery that ...


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