United States District Court, D. Nevada
CASTROVERDE LAW GROUP, ALEX J. DE CASTROVERDE, ESQ. Nevada
Bar No. 6950, ORLANDO DE CASTROVERDE, ESQ. Nevada Bar No.
7320, DAVID MENOCAL, ESQ. Nevada Bar No. 13191, KIMBERLY
VALENTIN, ESQ. Nevada Bar No. 12509, Attorneys for Plaintiff,
BRANDON BENDAVID MORAN, LEW BRANDON, JR., ESQ. Nevada Bar No.
5880, KRIS D. KLINGENSMITH, ESQ. Nevada Bar No. 13904,
Attorneys for Defendant, ALBERTSONS, LLC
STIPULATION AND ORDER FOR EXTENSION/MODIFICATION OF
DISCOVERY PLAN AND SCHEDULING ORDER (FOURTH REQUEST)
NOW Defendant, ALBERTSONS, LLC., by and through its
undersigned attorneys, LEW BRANDON, JR., ESQ. and KRIS D.
KLINGENSMITH, ESQ. of MORAN BRANDON BENDAVID MORAN, and
Plaintiff, by and through her attorneys, ALEX J. DE
CASTROVERDE, ESQ. and ORLANDO DE CASTROVERDE, ESQ., of DE
CASTROVERDE LAW GROUP, submit to the Court the following
Stipulation and Order for Extension/Modification of the
Discovery Plan and Scheduling Order (Fourth Request) pursuant
to LR IA 6-1, LR 26-4 (a) and Court Order Document No. 26.
Local Rule 6-1
LR IA 6-1(a) every stipulation to extend time must inform the
court of any previous extensions granted and state the reason
for the extension requested.
The Requirement of Local Rule 6-1 Are
the fourth request for extension filed by the parties. This
extension is requested to allow for the deposition of
Plaintiff's experts, Dr. Kaplan and Mr. Jennings, to be
Local Rule 26-4(a)
LR 26-4 (a) a statement specifying the Discovery completed:
parties have nearly completed the discovery phase in this
matter. Both sides have sent and received written discovery
in the form of Requests for Production, Requests for
Admissions and Interrogatories. The Plaintiff and the
percipient witnesses identified in her disclosures have been
deposed by Defendant. The Plaintiff has deposed
Defendant's FRCP 30(b)(6) witness and three of its
employees/former employees. Experts have been disclosed by
Local Rule 26-4(b)
LR 26-4(b) a specific description of the Discovery that
remains to be completed: The remaining Discovery to be
completed includes the depositions of Plaintiff's
Local Rule 26-4(c)
LR 26-4(c) the reasons why Discovery remaining was not
completed within the ...