United States District Court, D. Nevada
JAFFE & CLAYTON RILEY A. CLAYTON, ESQ., TROY A. CLARK,
ESQ. ATTORNEYS FOR DEFENDANT DENNY'S, INC.
RICHARD HARRIS LAW FIRM MICHAELA E. TRAMEL, ESQ. ATTORNEYS
FOR PLAINTIFF MONICA HINOSTROZA
STIPULATION AND ORDER TO EXTEND CURRENT DISCOVERY
DEADLINES I COMPLIANCE WITH LOCAL RULE 26-4
HEREBY STIPULATED by and between Plaintiff Monica Hinostroza
and Defendant Denny's, Inc., d/b/a Denny's
Restaurant, by and through their respective counsel of
record, and hereby stipulate to extend all current deadlines
by 84-days. Pursuant to Local Rule 6-1 (b), the parties state
that this is their third request for extension of discovery
FOR NECESSITY OF STIPULATION
parties stipulate that because Defendant has requested to
take an IME of Plaintiff. This IME requires Plaintiff to
travel from Massachusetts to Las Vegas. Defendant has also
agreed to take Plaintiffs deposition during this trip to
lesson Plaintiffs litigation expenses. The IME is now
scheduled to take place on July 19, 2018. Plaintiffs
deposition is set for July 18, 2018. Both of these events are
necessary for the formulation of expert opinions.
parties are also in the process of scheduling the accident
witness depositions. These witnesses are spread out in New
York and Massachusetts.
parties stipulate to continue discovery to allow for these
events to take place so that the experts can properly
formulate their opinions.
Defendant is still having issues obtaining out of state
records and thus request an extension to allow for a complete
history of Plaintiff s medical records for expert review and
formulation of opinions.
the parties are having a good faith dispute as to the scope
of some of the releases. The parties are in the process of
scheduling a Meet and Confer Conference regarding this issue
and if a Motion is necessary, there will be time necessary to
have the Motion heard and (potentially) records obtained with
result of the above, the parties agree to extend all current
deadlines by 84-days in compliance with Local Rule 26-1(e)
and Local Rule 26-4. The parties have good cause for seeking
this extension of the deadlines. This request for extension
is made by the parties and is made in good faith and not for
the purpose of delay, but to allow all parties sufficient
time to conduct necessary discovery.
Denny's Inc. exchanged FRCP 26(a) disclosures on November
Plaintiff exchanged FRCP 26(a) disclosures on November 15,
Denny's Inc. propounded its first set of written