United States District Court, D. Nevada
A. Ramirez, Mark C. Severino, WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP, Attorneys for defendant Costco
Lawrence M. Ruiz, Esq. Attorneys for Plaintiff.
JOINT MOTION/STIPULATION AND ORDER TO CONTINUE
DISCOVERY AND PRETRIAL DEADLINES (SECOND REQUEST)
above named parties, by and through their respective counsel
of record, hereby move the court and submit the following
STIPULATION/JOINT MOTION FOR EXTENSION OF DISCOVERY DEADLINES
DISCOVERY COMPLETED TO DATE
November 13, 2017, the parties held an initial rule 26(f)
Costco served its Rule 26 Initial Disclosures on November 30,
Plaintiff served her initial disclosures on February 5, 2018.
or about December 8, 2017, Costco propounded its first sets
of Interrogatories, Document Requests, and Requests for
Admissions onto the Plaintiff. Plaintiff provided responses
to Costco's Requests for Admissions on January 10, 2018.
Thereafter, plaintiff provided responses to Costco's
Interrogatories and Document Requests on February 6, 2018.
February 5, 2018, plaintiff served Costco with
Interrogatories and Document Requests. Costco served it
responses on April 19, 2018.
Plaintiff was deposed on February 27, 2018.
DISCOVERY THAT REMAINS TO BE COMPLETED
Deposition of plaintiff's treating physicians and/or
anticipated medical experts.
Deposition of Costco's person most knowledgeable.
Possible deposition of ...