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Flores v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

February 2, 2018

ROBERT FLORES, an individual, Plaintiff,
v.
WAL-MART STORES, INC., a foreign corporation d/b/a Wal-Mart Neighborhood Market #3355; JONATHAN SOROLA, an individual; DOES 1 through 10, inclusive; ROE CORPORATIONS 11 through 20, inclusive; and ABC LIMITED LIABILITY COMPANIES 21 through 30, inclusive, Defendants.

          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 REQUEST)

         Plaintiff, 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.

         STIPULATED APPLICATION

         WHEREAS, 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.

         A. DISCOVERY COMPLETED TO DATE

         1. The parties participated in the Fed. R. Civ. P 26(f) conference on August 15, 2017.

         2. 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.

         3. 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 16, 2017.

         4. 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.

         5. Defendant has taken the depositions of Cheri Adams and Plaintiff, Robert Flores.

         6. Plaintiff has taken the deposition of Defendant's cashier Jonathan Sorola.

         B. SPECIFIC DESCRIPTION OF THE DISCOVERY TO BE COMPLETED

         An 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 ...


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