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Trell v. McCune

United States District Court, D. Nevada

February 15, 2018

LYNN ELYSE TRELL, an individual, Plaintiff,
v.
STEPHEN F. MCCUNE, an individual; SWIFT TRANSPORTATION CO., LLC, a foreign limited-liability company; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.

          PANISH SHEA & BOYLE LLP, RAHUL RAVIPUDI, ESQ. Pending Pro Hac Admission GREGORIO V. SILVA, ESQ., Attorneys for Plaintiff Lynn Elyse Trell

          STEPHENSON & DICKINSON, P.C., BRUCE SCOTT DICKINSON, ESQ., JACQUELYN M. FRANCO, ESQ., Attorneys for Defendants Stephen F. McCune and Swift Transportation Co. of Arizona, LLC

          MAIER GUTIERREZ & ASSOCIATES, JASON R. MAIER, ESQ, JOSEPH A. GUTIERREZ, ESQ, Attorneys for Plaibntiff Lynn Elyse Trell

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (PROPOSED) (SECOND REQUEST)

         Pursuant to LR 6-1, 6-2 and LR 26-4, the parties by and through their respective counsel of record, hereby stipulate and request that the Court extend discovery in the above-captioned case as discussed herein. In support of this Stipulation and Request the parties state as follows:

         A. DISCOVERY CONDUCTED

         1. On May 17, 2017, Defendants filed a Petition for Removal.

         2. On May 30, 2017, the parties participated in a Federal Rule 26(f) conference.

         3. Plaintiff served her initial disclosure on June 15, 2017, and has since served five supplements.

         4. Defendants served their initial disclosures on July 19, 2017, and has since served seven supplements.

         5. Plaintiff propounded her first set of interrogatories, request for production of documents, and requests for admissions to Defendants on June 23, 2017.

         a. Defendants served their responses to Plaintiff's first set of request for admissions on August 9, 2017, b. Defendants served their responses to Plaintiff's first set of request for production of documents on August 23, 2017.

         c. Defendant Swift Transportation Co., LLC served its responses to Plaintiff's first set of interrogatories on August 25, 2017, and Mr. McCune served his responses to Plaintiff's first set of interrogatories on September 18, 2017.

         6. Defendant Stephen F. McCune propounded his first set of request for production of documents to Plaintiff on June 17, 2017.

         a. Plaintiff served her responses to Defendant Stephen F. McCune's First set of request for ...


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