United States District Court, D. Nevada
D. NETTLES, ESQ., WILLIAM R. KILLIP, JR., ESQ., JENNIFER A.
PETERSON, ESQ., Attorneys for Plaintiff.
BRANDON BENDAVID MORAN, MATTHEW WHITTAKER, ESQ., Attorney for
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE
DATES (FIRST REQUEST)
NOW, Plaintiff YVONN HEDMAN, by and through her attorneys
BRIAN D. NETTLES, ESQ., and WILLIAM R. KILLIP, JR., ESQ., and
JENNIFER A. PETERSON, ESQ., of the NETTLES LAW FIRM; and
Defendant ALBERTSON'S, LLC, by and through its attorneys
LEW BRANDON, JR., ESQ., and MATTHEW WHITTAKER, ESQ., of MORAN
BRANDON BENDAVID MORAN, and hereby submit the following
Stipulation pursuant to Local Rule 26-4. Based upon the
following, the Parties request this Court extend all
discovery deadlines by sixty (60) days. This request is made
in good faith and not to unduly delay the proceedings.
Local Rule 6-1
LR 6-1(b) every stipulation to extend time must inform the
court of any previous extensions granted and state the reason
for the extension requested.
The Requirement of Local Rule 6-1 Are Satisfied
the first request for extension filed by the parties. The
parties are seeking this extension in order to complete
additional discovery that could not be completed during the
Local Rule 26-4(a)
LR 26-4(a) a statement specifying the Discovery completed:
a. Initial disclosures have been exchanged between all
b. Written discovery has been expedited;
c. Defendant has scheduled the Custodian of Records
Depositions for January 5, 2018, at 8:00 a.m. for the
following treating providers:
1. St. Rose Dominican Hospital - Rose De Lima Campus;
2. Fremont Emergency Services;
3. Radiology Associates of Nevada;
4. Advanced Pain ...