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Calarco v. Sunrise Hospital & Medical Center LLC

United States District Court, D. Nevada

February 8, 2018

NANCY CALARCO, Plaintiff,
v.
SUNRISE HOSPITAL AND MEDICAL CENTER, LLC, Defendant.

          BRUCE C. YOUNG, ESQ., LEWIS BRISBOIS BISGAARD & SMITH LLP, Sunrise Hospital and Medical Center, LLC Attorneys for Defendant.

          SCOTT E. LUNDY, ESQ., REMPFER MOTT LUNDY, PLLC, Attorneys for Plaintiff.

          STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER DEADLINES (FIRST REQUEST)

         Pursuant to LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case sixty (60) days, up to and including April 30, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended in accordance with the discovery extension as outlined herein. In support of this Stipulation and Request, the parties state as follows:

         1. On June 16, 2017, Plaintiff filed her Complaint (ECF No. 1).

         2. On September 1, 2017, Defendant filed its Answer to the Complaint (ECF No. 13).

         3. On October 10, 2017, the parties prepared and filed their Proposed Discovery Plan and Scheduling Order (ECF No. 16). The Court approved and entered the Discovery Plan and Scheduling Order on October 11, 2017 (ECF No. 17).

         4. Defendant produced served its initial disclosures pursuant to Rule 26(a)(1) on November 6, 2017. Plaintiff served her initial disclosures pursuant to Rule 26(a)(1) on November 16, 2017.

         5. Defendant served written discovery requests (Interrogatories and Requests for Production of Documents) to Plaintiff on November 14, 2017. Plaintiff responded to the Interrogatories on December 29, 2017 and to the Requests for Production on January 2, 2018.

         6. The parties participated in an Early Neutral Evaluation ("ENE") on November 16, 2017.

         7. Plaintiff provided First Supplemental Responses to Defendant's Interrogatories, First Supplemental Responses to Defendant's Requests for Production and First Supplemental Disclosures on January 16, 2018.

         8. Plaintiff provided Second Supplemental Responses to Defendant's Requests for Production and Second Supplemental Disclosures on January 18, 2018.

         9. Plaintiff propounded Interrogatories and Requests for Production of Documents on Defendant on January 18, 2018. Defendant is in the process of obtaining information to respond to these written discovery requests.

         10. Plaintiffs deposition was scheduled to be taken on several occasions but has been continued due to conflicts with Plaintiffs work schedule and most recently as a result of an illness in the family of a ...


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