United States District Court, D. Nevada
NETTLES LAW FIRM, BRIAN D. NETTLES, ESQ, CHRISTIAN M. MORRIS,
ESQ, EDWARD J. WYNDER, ESQ., Attorneys for Plaintiff.
PHILLIPS, SPALLAS & ANGSTADT LLC, TIMOTHY D. KUHLS, ESQ,
Attorneys for Defendant.
STIPULATION TO EXTEND DISCOVERY DEADLINES (SECOND
Robert Flores (“Plaintiff”), by and through his
counsels of record, Brian D. Nettles, Esq. Christian M.
Morris, Esq., and Edward J. Wynder, Esq., of Nettles Law
Firm, and Defendant, Wal-Mart Stores, Inc. d/b/a Wal-Mart
Neighborhood Market #3355 (“Defendant”), by and
through its counsel of record, Timothy D. Kuhls, Esq., Esq.,
of Phillips, Spallas & Angstadt, LLC, hereby stipulate to
the extension of all remaining discovery deadlines by
sixty (60) days pursuant to LR 26-4.
the parties have begun discovery but are seeking in good
faith to settle this case while continuing to conduct
discovery to complete before trial, the parties request a
sixty (60) day extension of certain discovery deadlines as
set forth below.
DISCOVERY COMPLETED TO DATE
parties participated in the Fed. R. Civ. P 26(f) conference
on August 15, 2017.
Plaintiff made his pre-discovery disclosures pursuant to Fed.
R. Civ. P 26.1(a)(1) on August 28, 2017. Defendant served its
pre-discovery disclosures pursuant to Fed.R.Civ.P. 26.1(a)(1)
on September 15, 2017.
Defendant propounded written discovery to Plaintiff on
September 18, 2017 and Plaintiff responded to Requests for
Admissions on October 11, 2017 and Requests for Production of
Documents on October 16, 2017 and Interrogatories on October
Plaintiff propounded written discovery to Defendant on
November 1, 2017 and Defendant responded to Requests for
Admissions on December 4, 2017, Requests for Production of
Documents on December 18, 2017 and Interrogatories on
December 18, 2017.
Defendant has taken the depositions of Cheri Adams and
Plaintiff, Robert Flores.
Plaintiff has taken the deposition of Defendant's cashier
SPECIFIC DESCRIPTION OF THE DISCOVERY TO BE
Independent Medical Examination of the Plaintiff to be
conducted by a retained medical expert from Defendant and
initial Expert and Rebuttal disclosures. Additionally, the
parties intend to depose several individuals including
Defendant's Rule 30(b)(6) designee(s), treating ...