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De Blanc v. Aloha Airport Express

United States District Court, D. Nevada

May 1, 2018

SANDRA DE BLANC, Plaintiff,
v.
ALOHA AIRPORT EXPRESS, a Foreign Limited Liability Company; does 1 THROUGH 20; ROE BUSINESS ENTITIES 1 through 20, inclusive jointly and severally, Defendants.

          RICHARD HARRIS LAW FIRM Michaela E. Wood, Esq. Attorneys for Plaintiff

          WILSON ELSER MOSKOWITZ & DICKER LLP Christopher D. Phipps, Esq, Attorneys for Defendant

          STIPULATION AND ORDER FOR EXTENSION OF TIME TO COMPLETE DISCOVERY (FIRST REQUEST)

         The parties stipulate to an extension of discovery deadlines, currently set pursuant to the Stipulated Discovery Plan and Scheduling Order [Doc. #10] filed on March 7, 2018.

         I.DISCOVERY THAT HAS BEEN COMPLETED IN THIS MATTER INCLUDES THE FOLLOWING:

         The following discovery has been completed by the parties:

         1. Plaintiff received written discovery; 2. Plaintiff's Initial Disclosure; 3. Defendant's Initial 16.1 Disclosure.

         II. DISCOVERY THAT REMAINS TO BE COMPLETED:

         The discovery that remains to be completed includes, but is not limited to:

1. Initial expert disclosures;
2. Depositions of expert witnesses
3. Deposition of Person(s) Most Knowledgeable for Aloha Airport Express;
4. Deposition of Plaintiff;
5. Depositions of Plaintiff's treating providers; 6. Additional written ...

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