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Wetzel v. Medicwest Ambulance, Inc.

United States District Court, D. Nevada

December 22, 2017

ERIN WETZEL, an individual, Plaintiff,
v.
MEDICWEST AMBULANCE, INC., a Nevada corporation; and ENVISION HEALTHCARE CORPORATION, a Delaware corporation, Defendant.

          Steven J. Parsons, Law Offices of Steven J. Parsons, Attorneys for Plaintiff ERIN WETZEL.

          Matthew L. Durham, CHAD D. OLSON, Attorney for Defendants MEDICWEST AMBULANCE, INC. and ENVISION HEALTHCARE CORPORATION.

          STIPULATION AND JOINT MOTION FOR AN ORDER TO EXTEND THE DISCOVERY DEADLINES AND MODIFY THE SCHEDULING ORDER AND (PROPOSED) ORDER

         Plaintiff, ERIN WETZEL an individual, by her attorneys, Steven J. Parsons of Law Offices of Steven J. Parsons, and Defendants MEDICWEST AMBULANCE, INC., and ENVISION HEALTHCARE CORPORATION, by their attorneys, Daniel F. Fears, Matthew L. Durham and Chad D. Olsen of Payne & Fears, LLP, pursuant to LR IA 6-1 and LR 26-4, hereby stipulate and jointly move the Court for an Order that the Discovery Plan and Scheduling Order be modified to extend the close of discovery and other deadlines for ninety (90) days so that all pre-trial discovery may be completed.

         This Stipulation is filed for good cause and excusable neglect as set forth in the below, and not merely for delay.

         A. Discovery Completed

         Discovery completed in this matter to Dated:

1. The parties have exchanged initial disclosures;
2. Plaintiff served interrogatories and requests for production on each Defendant and Defendants have served their responses;
3. Defendants served Plaintiff with interrogatories and requests for production and Plaintiff has served her responses;
4. Defendants took Plaintiff's deposition on February 13, 2017, June 6, 2017, and July 27, 2017 - the Plaintiff's deposition has been completed;
5. Defendants issued subpoenas to third parties, including the North Las Vegas Police Department (“NLVPD”) and AT&T Wireless; and
6. Plaintiff took the deposition of two of Defendants' employees on November 30, 2017.

         B. Discovery that ...


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