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Foster v. Gnlv Corp

United States District Court, D. Nevada

April 3, 2018

JANET LYNN FOSTER, an individual, Plaintiff,
v.
GNLV, CORPORATION dba GOLDEN NUGGET LAS VEGAS HOTEL AND CASINO, a domestic corporation; DOE EMPLOYEE; DOES I through XXX, inclusive and ROE BUSINESS ENTITIES I through XXX, inclusive, Defendants.

          LADAH LAW FIRM, JOSEPH C. CHU NEVADA BAR NO. 11082, ATTORNEYS FOR PLAINTIFF JANET LYNN FOSTER

          PYATT SILVESTRI, RICHARD PYATT NEVADA BAR NO. 2777, ATTORNEYS FOR DEFENDANT GNLV CORPORATION DBA GOLDEN NUGGET LAS VEGAS HOTEL & CASINO

          STIPULATION AND ORDER TO RE-OPEN DISCOVERY AND EXTEND PRE-TRIAL DEADLINES (FIRST REQUEST)

         Plaintiff, JANET LYNN FOSTER (“Plaintiff”) and Defendant GNLV, CORPORATION dba GOLDEN NUGGET LAS VEGAS HOTEL AND CASINO (“Defendant”), by and through their undersigned counsel of record, hereby stipulate to reopen discovery for a period of 90 days and extend pre-trial deadlines, pursuant to LR 6-1 and LR 26-4. This is the parties' first stipulation to reopen discovery and extend pre-trial deadlines. The parties have not previously requested an extension of discovery.

         I. DISCOVERY COMPLETED TO DATE

         • Plaintiff served her Fed.R.Civ.P. 26 initial disclosure of witnesses and documents, and served two supplements thereto.

         • Defendant served their Fed.R.Civ.P. 26 initial disclosure of witnesses and documents, and served three supplements thereto.

         • Defendant served Plaintiff with written discovery requests, and Plaintiff has served responses thereto.

         • Plaintiff served Defendant with written discovery requests, and Defendant has served responses thereto.

         • Defendant has taken the deposition of Plaintiff.

         • Plaintiff has taken the deposition of Defendant's employee and security officer Noel Vega.

         II. DISCOVERY SCHEDULED, BUT NOT YET COMPLETED

         Prior to the close of discovery, Plaintiff served timely notices of deposition of the following witnesses:

         • Defendant's Corporate Representative/30(b)(6) Designee as ...


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