United States District Court, D. Nevada
LAW FIRM, JOSEPH C. CHU NEVADA BAR NO. 11082, ATTORNEYS FOR
PLAINTIFF JANET LYNN FOSTER
SILVESTRI, RICHARD PYATT NEVADA BAR NO. 2777, ATTORNEYS FOR
DEFENDANT GNLV CORPORATION DBA GOLDEN NUGGET LAS VEGAS HOTEL
STIPULATION AND ORDER TO RE-OPEN DISCOVERY AND EXTEND
PRE-TRIAL DEADLINES (FIRST REQUEST)
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.
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
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.
DISCOVERY SCHEDULED, BUT NOT YET COMPLETED
to the close of discovery, Plaintiff served timely notices of
deposition of the following witnesses:
Defendant's Corporate Representative/30(b)(6) Designee as