United States District Court, D. Nevada
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
STIPULATION AND JOINT MOTION FOR AN ORDER TO EXTEND
THE DISCOVERY DEADLINES AND MODIFY THE SCHEDULING ORDER AND
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
Stipulation is filed for good cause and excusable neglect as
set forth in the below, and not merely for delay.
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
3. Defendants served Plaintiff with interrogatories and
requests for production and Plaintiff has served her
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.
Discovery that ...