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Flores v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

March 20, 2018

ROBERT FLORES, an individual, Plaintiff,
v.
WAL-MART STORES INC., a foreign corporation d/b/a Wal-Mart Neighborhood Market #3355; DOES 1 through 10, inclusive; ROE CORPORATIONS 11 through 20, inclusive; and ABC LIMITED LIABILITY COMPANIES 21 through 30, inclusive, Defendants.

          NETTLES LAW FIRM, BRIAN D. NETTLES, ESQ, CHRISTIAN M. MORRIS, ESQ, EDWARD J. WYNDER, ESQ, Attorneys for Plaintiff

          PHILLIPS, SPALLAS & ANGSTADT LLC, ROBERT K. PHILLIPS, ESQ., TIMOTHY D. KUHLS, ESQ., Attorneys for Defendants Wal-Mart Stores, Inc. d/b/a Wal-Mart Neighborhood Market No. 3355

          STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES [THIRD REQUEST]

         Plaintiff ROBERT FLORES (hereinafter “Plaintiff”) and Defendant WAL-MART STORES, INC. d/b/a WAL-MART NEIGHBORHOOD MARKET No. 3355 (hereinafter “Wal-Mart” or “Defendant”), by and through their respective counsel of record, do hereby stipulate to extend the remaining deadlines in the current scheduling order and discoverfy plan in this matter for a period of sixty (60) days for the reasons explained herein.

         Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the third such discovery extension requested in this matter.

         DISCOVERY COMPLETED TO DATE

         • The parties conducted the FRCP 26(f) conference on August 15, 2017 and served their respective FRCP 26(a) disclosures on August 28, 2017 and September 15, 2017, respectively;

         • Defendant served upon Plaintiff one set of Requests for Production, an initial set of Interrogatories and its initial set of Requests for Admissions on September 18, 2017. Plaintiff submitted timely responses to Defendant's Requests for Admissions on October 11, 2017. Plaintiff submitted timely responses to Defendant's Initial Requests for Production and Interrogatories on October 16, 2017;

         • Plaintiff served upon Defendant one set of Interrogatories, one set of Request for Production of Documents and one set of Requests for Admissions on November 1, 2017. Defendant submitted timely responses to Plaintiffs initial set of Requests for Admissions on December 4, 2017. Defendant submitted timely responses to Plaintiffs initial set of Requests for Production of Documents and Interrogatories on December 18, 2017. Defendant then served its First Supplemental Responses to Plaintiffs first set of Requests for Production of Documents on December 19, 2017;

         • Defendant timely noticed and took Plaintiffs deposition on November 8, 2017;

         • Defendant timely noticed and Plaintiff wilfully attended a FRCP 35 examination with Defendant's expert physician on July 13, 2017;

         • Defendant timely noticed and took the deposition of Plaintiffs significant other, Ms. Cheri Adams, on November 6, 2017;

         • Plaintiff timely noticed and took Defendant's former employee, Mr. Jonathan Sorola's, deposition on November 28, 2017;

         • Defendant timely noticed and took Plaintiffs deposition on January 5, 2018; and

         • Defendant timely noticed and Plaintiff appeared for his FRCP 35 examination with Defendant's retained medical expert ...


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