United States District Court, D. Nevada
SPRINGEL & FINK LLP LEONARD T. FINK, ESQ. Nevada Bar No.
6296 NAKESHA S. DUNCAN, ESQ. Nevada Bar No. 11556
& TADAYON LEWIS GAZDA, ESQ. Nevada Bar No. 4269 AFSHIN
TADAYON, ESQ. Nevada Bar No. 6517
STIPULATION TO EXTEND DISCOVERY
parties, by and through their respective, undersigned,
attorneys of record, hereby submits this Stipulation and
Order to Extend Discovery Deadlines, as detailed below.
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
following discovery has been completed:
1. Plaintiff and Defendants have exchanged FRCP 26
disclosures of witnesses and documents, and supplements
2. Defendant SECURITAS SECURITY SERVICES USA, INC. has
propounded written discovery upon Plaintiff.
3. Plaintiff has propounded written discovery upon
4. Defendants have responded to Plaintiff's written
5. Plaintiff has responses to Defendants' written
6. An independent medical examination of Plaintiff has been
7. Defendants have disclosed their initial expert witness.
Discovery that ...