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Hedman v. Albertsons LLC

United States District Court, D. Nevada

January 10, 2018

YVONN HEDMAN, an individual, Plaintiff,
v.
ALBERTSON'S, LLC, a Foreign Limited Liability Company; DOE INDIVIDUALS 1 through 10; ROE CORPORATIONS 11 through 20; and ABC LIMITED LIABILITY COMPANIES 21 through 30, inclusive, Defendants.

          BRIAN D. NETTLES, ESQ., WILLIAM R. KILLIP, JR., ESQ., JENNIFER A. PETERSON, ESQ., Attorneys for Plaintiff.

          MORAN BRANDON BENDAVID MORAN, MATTHEW WHITTAKER, ESQ., Attorney for Defendant.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE DATES (FIRST REQUEST)

         COME 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.

         I. Local Rule 6-1

         Under 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.

         a. The Requirement of Local Rule 6-1 Are Satisfied

         This is 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 time allotted.

         II. Local Rule 26-4(a)

         Under LR 26-4(a) a statement specifying the Discovery completed:

a. Initial disclosures have been exchanged between all parties;
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 ...

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