United States District Court, D. Nevada
BERYL NICOLE FOSTER-HENRY, and DEONNE HENRY, an individually. Plaintiff,
ARMY AND AIR FORCE EXCHANGE SERVICE; ANDREWS & COMPANY, NJ., LLC, dba ANDREWS & COMPANY, LLC; DEPARTMENT OF DEFENSE; UNITED STATE OF AMERICAN EX REL NELLIS AIR FORCE BASE, UNITED STATE OF AMERICA EX REL DEPARTMENT OF THE AIR FORCE, NELLIS AIR FORCE BASE EXCHANGE; ARMY AND AIR FORCE EXCHANGES SERVICES; ANDREWS AND COMPANY, LLC; DEPARTMENT OF DEFENSE. Defendants.
ROBERTS STOFFEL FAMILY LAW GROUP, Amanda M. Roberts, Esq.
State Bar of Nevada No. 9294 Attorneys for Plaintiff
ELIESON UNITED STATES ATTORNEY, Patrick A. Rose, Esq.
Assistant United States Attorney
STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST
and the United States stipulate to, and request an order
approving, an extension of discovery deadlines as, and for
the reasons set forth below. This is the first request for an extension
of discovery deadlines.
any adverse waiver or admission as to claims, defenses, or
positions, the parties advise that this case arises out of an
incident on July 1, 2014, in which Plaintiff Beryl Nicole
Foster-Henry alleges that she slipped and fell on a slippery
substance on the floor of the food court at Nellis Air Force
connection with the Rule 26(f) conference, the parties served
their respective initial disclosures of documents and
has been in the process of collecting medical records
pursuant to a HIPAA authorization provided by Plaintiff Beryl
Beryl Nicole Foster-Henry served a first set of written
discovery requests on January 12, 2018.
That Remains to be Completed:
discovery and depositions remain.
Why Remaining Discovery Was Not Completed, and Otherwise the
Good Cause for the Requested Extension:
Counsel will be out of the office for several days in the
near future for personal/medical reasons. Defense Counsel
would likely need an extension of the deadline for defense
expert disclosures (as well as to respond to Plaintiff's
written discovery requests). Rather than seeking a unilateral
extension after Plaintiff served any expert disclosures (on
the existing deadline of January 25, 2018), Defense Counsel
recently contacted Plaintiff's Counsel about extending
Plaintiff's expert disclosure deadline as well. As a
result, this request is submitted more than twenty-one days
before every existing deadline except that for
Plaintiff's expert disclosures.
Schedule for Completing ...