Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Foster-Henry v. Army and Air Force Exchange Service

United States District Court, D. Nevada

February 2, 2018

BERYL NICOLE FOSTER-HENRY, and DEONNE HENRY, an individually. Plaintiff,
v.
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

          DAYLE ELIESON UNITED STATES ATTORNEY, Patrick A. Rose, Esq. Assistant United States Attorney

          STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST)

         Plaintiffs and the United States stipulate to, and request an order approving, an extension of discovery deadlines as, and for the reasons set forth below.[1] This is the first request for an extension of discovery deadlines.

         Without 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 Base.

         Discovery Completed

         In connection with the Rule 26(f) conference, the parties served their respective initial disclosures of documents and witnesses.

         Defendant has been in the process of collecting medical records pursuant to a HIPAA authorization provided by Plaintiff Beryl Nicole Foster-Henry.

         Plaintiff Beryl Nicole Foster-Henry served a first set of written discovery requests on January 12, 2018.

         Discovery That Remains to be Completed:

         Written discovery and depositions remain.

         Expert disclosures remain.

         Reasons Why Remaining Discovery Was Not Completed, and Otherwise the Good Cause for the Requested Extension:

         Defense 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.

         Proposed Schedule for Completing ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.