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Zapinski v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

February 12, 2018

MICHELLE ZAPINSKI, an individual; Plaintiffs,
v.
WAL-MART STORES, INC., a foreign corporation d/b/a WAL-MART SUPERCENTER #1584; DOES 1 through 10, inclusive; ROE CORPORATIONS 11 through 20, inclusive; and ABC LIMITED LIABILITY COMPANIES 21 through 30, inclusive, Defendants.

          NETTLES LAW FIRM JENNIFER A. PETERSON, ESQ. Nevada Bar No. 11242 1389 Galleria Drive, Suite 200 Henderson, Nevada 89014 Attorneys for Plaintiff

          PHILLIPS, SPALLAS & ANGSTADT LLC RYAN KERBOW, ESQ. Attorneys for Defendant

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE DATES (SECOND REQUEST)

         COME NOW, Plaintiff MICHELLE ZAPINSKI, by and through her attorneys BRIAN D. NETTLES, ESQ., and WILLIAM R. KILLIP, JR., ESQ., and JENNIFER A. PETERSON, ESQ., of the NETTLES LAW FIRM; and Defendant WAL-MART STORES, INC. d/b/a WAL-MART SUPERCENTER #1584, by and through their attorneys ROBERT K. PHILLIPS, ESQ., and RYAN KERBOW, ESQ., of PHILLIPS, SPALLAS & ANGSTADT, LLC, and hereby submit the following Stipulation pursuant to Local Rule 26-4. Based upon the following, the Parties request this Court extend all discovery deadlines by forty-five (45) days. This request is made in good faith and not to unduly delay the proceedings.

         I. Local Rule 6-1

         Under LR 6-1(b) every stipulation to extend time must inform the court of any previous extensions granted and state the reason for the extension requested.

         a. The Requirement of Local Rule 6-1 Are Satisfied

         This is the second request for extension filed by the parties. The first extension was granted on November 13, 2017. The parties are seeking this extension in order to attend mediation prior to engaging in additional expert discovery.

         II. Local Rule 26-4(a)

         Under LR 26-4(a) a statement specifying the Discovery completed:

a. Initial disclosures have been exchanged between all parties.
b. Written discovery has been expedited.
c. Plaintiff Michelle Zapinski has had her deposition taken
d. Plaintiffs Orthopedic Surgeon, Yevgeniy Khavkin, M.D., has ...

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