United States District Court, D. Nevada
C. YOUNG, ESQ., LEWIS BRISBOIS BISGAARD & SMITH LLP,
Sunrise Hospital and Medical Center, LLC Attorneys for
E. LUNDY, ESQ., REMPFER MOTT LUNDY, PLLC, Attorneys for
STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER
DEADLINES (FIRST REQUEST)
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:
June 16, 2017, Plaintiff filed her Complaint (ECF No. 1).
September 1, 2017, Defendant filed its Answer to the
Complaint (ECF No. 13).
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).
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,
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.
parties participated in an Early Neutral Evaluation
("ENE") on November 16, 2017.
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.
Plaintiff provided Second Supplemental Responses to
Defendant's Requests for Production and Second
Supplemental Disclosures on January 18, 2018.
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.
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 ...