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McKenzie v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

January 8, 2018

DEBORAH MCKENZIE, Plaintiff,
v.
WAL-MART STORES INC.; and DOES 1 through 100; and ROE CORPORATIONS 101 through 200, inclusive, Defendants.

          ROBERT K. PHILLIPS Nevada Bar No. 11441 Attorneys for Defendant Wal-Mart Stores, Inc.

          Sean J. Akari, Esq. Nevada Bar No. 13300 BERNSTEIN & POISSON Attorneys for Plaintiff

          Betsy Jefferis, Esq. Nevada Bar No. 12980 PHILLIPS SPALLAS & ANGSTADT Attorneys for Defendant Wal-Mart Stores, Inc.

          STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES [FIRST REOUEST]

         Plaintiff Deborah McKenzie, (hereinafter "Plaintiff) and Defendant WAL-MART STORES, INC. (hereinafter "WALMART" or "Defendant"), by and through their respective counsel of record, do hereby stipulate to extend the remaining deadlines in the current scheduling order and discovery plan in this matter for a period of sixty (60) days for the reasons explained herein.

         Pursuant to Local Rule 6-1 (b), the parties hereby aver that this is the First such discovery extension requested in this matter.

         DISCOVERY COMPLETED TO DATE

• The parties have conducted an FRCP 26(f) conference and have served their respective FRCP 26(a) disclosures;
• Plaintiff served their Initial Disclosures on December 14, 2017
• Defendant served their Initial Disclosures on December 8, 2017
• Defendant has received executed authorizations for plaintiff and has requested medical records on December 22, 2017.

         DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF DISCOVERY

         Discovery to be completed includes:

• Plaintiff s and Defendant's Written Discovery request(s);
• Deposition of Plaintiff Deborah McKenzie (Currently set ...

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