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Ruiz-Camacho v. Costco Wholesale Corp.

United States District Court, D. Nevada

April 13, 2018

EVA RUIZ-CAMACHO, Plaintiff,
v.
COSTCO WHOLESALE CORPORATION; DOES I-X, inclusive, and ROE CORPORATIONS I-X, inclusive, Defendants.

          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 DEADLINE

         Pursuant 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.

         I.

         STATEMENT SPECIFYING DISCOVERY COMPLETED

         1. The parties have made their initial disclosures of witnesses and documents and multiple supplements thereto.

         2. The parties have engaged in numerous sets of written discovery.

         3. The parties have made initial and rebuttal expert disclosures.

         4. 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 executed authorizations:

a. Tax Form 4506;
b. Medicaid authorization;
c. Medicare authorization;
d. Sierra Health HMO authorization;
e. Health Plan of Nevada ...

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