United States District Court, D. Nevada
JAFFE & CLAYTON Riley A. Clayton, Esq. Siria L.
Gutiérrez, Esq. Attorneys for Defendant Denny's,
RICHARD HARRIS LAW FIRM Michaela E. Tramel, Esq. Attorneys
for Plaintiff Monica Hinostroza.
STIPULATION AND ORDER TO EXTEND CURRENT DISCOVERY
DEADLINES I COMPLIANCE WITH LOCAL RULE 26-4 FIRST
HEREBY STIPULATED by and between Plaintiff Monica Hinostroza
and Defendant Denny's, Inc., d/b/a Denny's
Restaurant, by and through their respective counsel of
record, and hereby stipulate to extend all current deadlines
by 60-days. Pursuant to Local Rule 6-1(b), the parties state
that this is their first request for extension of discovery
FOR NECESSITY OF STIPULATION
parties stipulate that because this matter involves extensive
medical treatment incurred by Plaintiff Monica Hinostroza in
Boston, Massachusetts, between the time of the alleged
incident on February 22, 2016, and the filing of this
lawsuit, the parties need additional time to evaluate,
retain, and receive expert reports from their respective
experts. The parties have been diligently working together to
attempt to complete discovery within the time period;
however, Plaintiff being out-of-state has caused unforeseen
delays. Additionally, Denny's first notice of the claim
was the lawsuit itself and it continues to investigate this
claim, including the possibility that the alleged fall
occurred on a different premises or may necessitate the
inclusion of other parties.
result of the delays in obtaining records from across the
U.S. and questions about the location of the fall, the
parties agree to extend all current deadlines by 60-days in
compliance with Local Rule 26-1(e) and Local Rule 26-4. The
parties have good cause for seeking this extension of the
deadlines. This request for extension is made by the parties
and is made in good faith and not for the purpose of delay,
but to allow all parties sufficient time to conduct necessary
• Denny's Inc. exchanged FRCP 26(a) disclosures on
November 9, 2017.
• Plaintiff exchanged FRCP 26(a) disclosures on November
• Denny's Inc. propounded its first set of written
discovery on Plaintiff November 9, 2017.
• Plaintiff propounded written discovery on Denny's
Inc. on December 6, 2017.
• Denny's Inc. and Plaintiff have been diligently
requesting Plaintiff's medical records.
• Denny's Inc. anticipates taking the deposition of
Plaintiff, Jose Hinostroza, and Plaintiff's treating