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Hinostroza v. Denny's Inc.

United States District Court, D. Nevada

March 29, 2018

MONICA HINOSTROZA, Plaintiff,
v.
DENNY'S, INC., d/b/a DENNY'S RESTAURANT, a Foreign corporation, DOES 1 through 20; ROE BUSINESS ENTITIES 1 through 20, inclusive jointly and severally, Defendants.

          HALL, 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

         IT IS 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 deadlines.

         REASONS FOR NECESSITY OF STIPULATION

         The 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.

         The parties are also in the process of scheduling the accident witness depositions. These witnesses are spread out in New York and Massachusetts.

         The parties stipulate to continue discovery to allow for these events to take place so that the experts can properly formulate their opinions.

         Furthermore, 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.

         Finally, 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 said releases.

         As a 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.

         DISCOVERY COMPLETED

         • Denny's Inc. exchanged FRCP 26(a) disclosures on November 9, 2017.

         • Plaintiff exchanged FRCP 26(a) disclosures on November 15, 2017.

         • Denny's Inc. propounded its first set of written discovery ...


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