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Nitta v. United States

United States District Court, D. Nevada

April 9, 2018

KAYSEE NITTA, Plaintiff,
v.
UNITED STATES OF AMERICA, Defendants.

          SGRO & ROGER ANTHONY P. SGRO, ESQ., EUNICE M. BEATTIE, ESQ. ATTORNEYS FOR PLAINTIFF

          UNITED STATES OF AMERICA PATRICK A. ROSE, ESQ. ATTORNEYS FOR DEFENDANT

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Pursuant to LR 6-1 and LR 26-4, Plaintiff requests, and Defendant does not oppose, and hereby stipulate that this Court extend discovery in the above-captioned case sixty (60) days, pursuant to Plaintiffs request, which would extend discovery up to and including Monday, September 17, 2018. In addition, the parties stipulate that the dispositive motions and pretrial order deadlines be extended for an additional sixty (60) days as outlined herein, in support of Plaintiffs request. In support of this Stipulation and Request, the parties state as follows:

1. On April 24, 2017, Plaintiff filed her Complaint in United States District Court, District of Nevada.
2. On June 23, 2017, Defendant filed its Answer.
3. On August 28, 2017, the parties submitted a proposed scheduling order to the Court.
4. On September 20, 2017, Plaintiff received Defendant's 26.1 list of witnesses and documents.
5. On September 21, 2017, Plaintiff served her 26.1 list of witnesses and documents.
6. On November 6, 2017, Plaintiff propounded written discovery on Defendant.
7. On December 21, 2017, Defendant served its responses to Plaintiff.
8. On January 2, 2018, Plaintiff noticed the depositions of two lay witnesses, Ana Smith, and Natalie Weckesser.
9. On January 3, 2018, Defendant propounded written discovery on Defendant. Since this time, more written discovery has been conducted, medical records have been requested, more depositions have been taken (including Plaintiffs deposition), and more depositions have been noticed or are anticipated to occur in the near future.

         DISCOVERY ...


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