United States District Court, D. Nevada
STOVALL & ASSOCIATES LESLIE MARK STOVALL, ESQ. ROSS H.
MOYNIHAN, ESQ. Attorneys for plaintiff
CHRISTOPHER PHIPPS, ESQ. WILSON, ELSER, MOSKOWITZ EDELMAN
& DICKER, LLP Attorneys for Defendant
STIPULATION AND ORDER TO EXTEND THE CLOSE OF DISCOVER
to LR 26-4, and for reasons provided below, the parties, by
and through their respective counsel request that the court
extend the close of discovery date by 60 days so that the
parties can complete discovery and ready this case for trial.
This is the fifth such request for an extension of time.
SPECIFYING DISCOVERY COMPLETED
parties have made their initial disclosures of witnesses and
documents and multiple supplements thereto.
parties have engaged in numerous sets of written discovery.
parties have made initial and rebuttal expert disclosures.
Following a discovery dispute, the parties' request for
guidance on the dispute from the court, and the court's
ruling on the matter (see ECF No. 32, dated January 9, 2018),
the plaintiff provided the defendant with the following
a. Tax Form 4506;
b. Medicaid authorization;
c. Medicare authorization;
d. Sierra Health HMO authorization;
e. Health Plan of Nevada ...