United States District Court, D. Nevada
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)
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.
Local Rule 6-1
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.
The Requirement of Local Rule 6-1 Are
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.
Local Rule 26-4(a)
LR 26-4(a) a statement specifying the Discovery completed:
a. Initial disclosures have been exchanged between all
b. Written discovery has been expedited.
c. Plaintiff Michelle Zapinski has had her deposition taken
d. Plaintiffs Orthopedic Surgeon, Yevgeniy Khavkin, M.D., has