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Valle v. Home Depot U.S.A., Inc.

United States District Court, D. Nevada

January 24, 2018

ROXANNA VALLE, an individual, Plaintiff,
v.
HOME DEPOT U.S.A., INC., a foreign corporation; DOE EMPLOYEE; DOES I through XXX, inclusive, and ROE BUSINESS ENTITIES I through XXX, inclusive, Defendants.

          LADAH LAW FIRM RAMZY PAUL LADAH, ESQ. Nevada Bar No. 11405 ANTHONY L. ASHBY, ESQ. Nevada Bar No. 4911 JOSEPH CHU, ESQ. Nevada Bar No. 11082 Attorneys for Plaintiff, Roxanna Valle

          DENNETT WINSPEAR, LLP RYAN L. DENNETT, ESQ. Matthew J. Wagner Nevada Bar No. 005617 MATTHEW J. WAGNER, ESQ. Nevada Bar No. 011311 Attorneys for Defendant, Home Depot U.S.A., Inc.

          STIPULATION FOR EXTENSION OF TIME TO COMPLETE DISCOVERY (FIRST REQUEST)

         COME NOW the parties, by and through their respective counsel, and move the Honorable Magistrate Judge for an Order continuing Discovery and submit the instant Stipulation in accordance with LR 6-1 and LR 26-4. The parties have conferred and agree that an extension of discovery is both necessary and warranted.

         No previous requests or extensions for time in which to complete discovery in this matter have been requested. However, for reasons outlined in the original Discovery Plan, the parties requested special scheduling review regarding the deadlines contained within the Stipulated Discovery Plan and Scheduling Order (Document #9) as the dates originally requested were longer than those specified in Local Rule 26-1(e). The court granted the requested initial deadlines for discovery.

         An extension of time for discovery is necessary and good cause exists for the extension pursuant to Local Rule 26-4. Pursuant to that Rule, the parties submit the following:

         (a) DISCOVERY THAT HAS BEEN COMPLETED

         Counsel for the respective parties participated in a discovery planning conference pursuant to Fed.R.Civ.P. 26(f). Lists of witnesses and document productions were thereafter exchanged by and between the parties. A Proposed Discovery Plan was filed on October 6, 2017.

         On November 14, 2017, Defendant served its initial Disclosure of Witnesses and Documents.

         On or about November 14, 2017, Defendant served written discovery on Plaintiff, consisting of interrogatories, requests for production of documents, and requests for admissions.

         On December 12, 2017, Plaintiff served her initial Disclosure of Witnesses and Documents.

         On or about December 12, 2017, Plaintiff served written discovery on Defendant, consisting of interrogatories, requests for production of documents, and requests for admissions. Responses to the discovery are pending based on an extension of time agreed-to by the parties.

         On December 13, 2017, Plaintiff served responses to requests for admissions. Responses to the remaining discovery are pending based on an extension of time agreed-to by the parties.

         (b) DISCOVERY THAT REMAINS TO BE COMPLETED

         The parties are currently conducting additional factual and expert discovery, including depositions of Plaintiff Valle and of the parties affiliated with Defendant Home Depot ...


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