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Angelo v. Albertson's LLC

United States District Court, D. Nevada

March 26, 2018

THOMAS ANGELO, an Individual; and KAREN ANGELO, an Individual, Plaintiff,
v.
ALBERTSON'S LLC., d/b/a ALBERTSON'S, a Foreign Limited-Liability Company; and DOES I through X, inclusive; and ROE BUSINESS ENTITIES I through X, inclusive, Defendants.

          JOHN B. SHOOK, ESQ. Nevada Bar No. 5499 710 South Fourth Street Las Vegas, NV 89101 (702) 385-2220 Attorneys for Plaintiffs

          BACKUS, CARRANZA & BURDEN JACK P. BURDEN, ESQ. Nevada Bar No. 6918 XIAO WEN JIN, ESQ. Nevada Bar No. 13901 Attorneys for Defendants

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         IT IS HEREBY STIPULATED AND AGREED, by Plaintiffs and Defendants, by and through their undersigned counsel, that discovery be extended beyond the Discovery Schedule in the Stipulation and Order to Extend Discovery dated October 18, 2017 (Document No. 14).

         Per Federal Rules of Civil Procedure 16(b), and Local Rule 26-4 the following is included in support of the proposed extension to the Discovery Schedule:

         A. STATEMENT SPECIFYING THE DISCOVERY THAT HAS BEEN COMPLETED.

         The parties participated in the Fed.R.Civ.P. 26(f) conference on June 22, 2017. The parties have propounded and responded to written discovery requests including Interrogatories, Request for Production of Documents and Requests for Admission. The depositions of Plaintiff, Thomas Angelo and Karen Angelo were completed on October 30, 2017. The deposition of Defendant's employee, Kenneth Luoto was completed on June 3, 2018 and the deposition of Defendant's store manager, Mignon Pasqualicchio was completed on January 19, 2018. Plaintiffs currently have the depositions of additional Defendant's employees scheduled for March 27, 2018 and March 28, 2018. The parties disclosed expert reports on February 21, 2018 and the parties disclosed rebuttal expert reports on March 22, 2018.

         B. SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED.

         As set forth above, the parties agree that an extension in the discovery deadlines is necessary to ensure this case is prepared for trial. The Plaintiffs will need additional time to depose the FRCP 30(b)(6) Corporative Representative of Defendant Albertson's in addition to the expert witnesses Defendants have disclosed.

         Defendants will also need to conduct the depositions of Plaintiff's treating physicians and the expert witnesses Plaintiffs' have disclosed.

         C. REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE DEADLINES CONTAINED IN THE AMENDED DISCOVERY SCHEDULING ORDER

         Despite the parties' good faith efforts to comply with the Court's discovery deadlines, both parties have been compromised in part by the numerous experts that will need to be deposed and the extent of Plaintiff's treating physicians. As such, the parties believe that a ninety (90) extension of the discovery cut off date will be sufficient to allow the parties to complete discovery.

         D. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY.

         It is requested that all remaining discovery deadlines in this case ...


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