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Hinostroza v. Denny's, Inc.

United States District Court, D. Nevada

December 28, 2017

MONICA HINOSTROZA, Plaintiff,
v.
DENNY'S, INC., d/b/a DENNY'S RESTAURANT, a Foreign corporation, DOES 1 through 20; ROE BUSINESS ENTITIES 1 through 20, inclusive jointly and severally, Defendants.

          HALL, JAFFE & CLAYTON Riley A. Clayton, Esq. Siria L. Gutiérrez, Esq. Attorneys for Defendant Denny's, Inc.

          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 REQUEST

         IT IS 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 deadlines.

         REASONS FOR NECESSITY OF STIPULATION

         The 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.

         As a 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 discovery.

         DISCOVERY COMPLETED

• Denny's Inc. exchanged FRCP 26(a) disclosures on November 9, 2017.
• Plaintiff exchanged FRCP 26(a) disclosures on November 15, 2017.
• 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.

         DISCOVERY PENDING

• Denny's Inc. anticipates taking the deposition of Plaintiff, Jose Hinostroza, and Plaintiff's treating ...

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