United States District Court, D. Nevada
& ROGER ANTHONY P. SGRO, ESQ., EUNICE M. BEATTIE, ESQ.
ATTORNEYS FOR PLAINTIFF
STATES OF AMERICA PATRICK A. ROSE, ESQ. ATTORNEYS FOR
STIPULATION AND ORDER TO EXTEND DISCOVERY
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
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.