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Nitta v. United States

United States District Court, D. Nevada

January 5, 2018

KAYSEE NITTA, Plaintiff,
v.
UNITED STATES OF AMERICA, Defendants.

          EUNICE M. BEATTIE, ESQ. ANTHONY P. SGRO, ESQ, ATTORNEYS FOR PLAINTIFF

          PATRICK A. ROSE, ESQ. ATTORNEYS FOR DEFENDANT

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case ninety (90) days, up to and including July 18, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days as outlined herein. In support of this Stipulation and Request, the parties state as follows:

         1. On April 24, 2017, Plaintiff filed her Complaint in United States District Court, District of Nevada.

         2. On June 23, 2017, Defendant filed its Answer.

         3. On August 28, 2017, the parties submitted a proposed scheduling order to the Court.

         4. On September 20, 2017, Plaintiff received Defendant's 26.1 list of witnesses and documents.

         5. On September 21, 2017, Plaintiff served her 26.1 list of witnesses and documents.

         6. On November 6, 2017, Plaintiff propounded written discovery on Defendant.

         7. On December 21, 2017, Defendant served its responses to Plaintiff.

         8. On January 2, 2018, Plaintiff noticed the depositions of two lay witnesses, Ana Smith, and Natalie Weckesser.

         9. On January 3, 2018, Defendant propounded written discovery on Defendant.

         DISCOVERY REMAINING

         1. Plaintiff will take the deposition of Defendant. Defendant will ...


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