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Macias v. Bodega Latina Corp.

United States District Court, D. Nevada

May 8, 2018

LUZ T. MACIAS, Individually, Plaintiff,
v.
BODEGA LATINA CORPORATION, d/b/a EL SUPER, a Foreign Corporation; DOES 1 through 20; ROE CORPORATIONS 1 through 20, inclusive, Defendant.

          MICHAEL C. MILLS, ESQ. BAUMAN LOEWE WITT & MAXWELL Attorneys for Defendant, Bodega Latina Corporation dba El Super

          LUZ MACIAS

          STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND DEADLINES (FIRST REQUEST)

         Plaintiff Isabel Torres In Proper Person and Defendant Bodega Latina Corporation, by and through their counsel, and pursuant to Local Rule 26-4, stipulate to modify their discovery plan as follows:

         1. Plaintiff filed her Complaint on August 1, 2017 in the Eighth Judicial District Court, Case No. A-17-759247-C. Defendant filed their Answer and Jury Demand on August 24, 2017. This case was removed to the United States District Court on September 7, 2017. Plaintiff's counsel filed a Motion to Withdraw and it was granted on October 23, IZUT7. A status hearing was held on January 4, 2018.

         2. The parties held their F.R.C.P. 26 conference on January 5, 2018 and filed their Stipulated Discovery Plan and Scheduling Order on January 17, 2018. In this original plan, the parties agreed to the following dates:

Last Day to Amend Pleadings:

04/04/2018

Expert Disclosure Deadline:

05/04/2018

Interim Status Report Deadline:

05/04/2018

Rebuttal Expert Disclosure:

06/04/2018

Discovery Cut-Off:

07/03/2018

Dispositive Motions Deadline:

08/02/2018

Pre-Trial Order:

09/04/2018

         The initial discovery plan was signed by United States Magistrate Peggy A. Leen, January 23, 2018.

         3. In compliance with Local Rule 26-4, the parties provide the following information regarding the discovery status:

         (a) Discovery Completed pursuant to Fed.R.Civ.P. 26(a):

Defendants:

Interrogatories to Plaintiff

11/01/2017

Request for Production to Plaintiff

11/01/2017

Initial Disclosure

11/03/2017

First Supplemental Disclosure

01/22/2018

Second Supplemental Disclosure

02/27/2018

Third Supplemental Disclosure

03/28/2018

Fourth Supplemental Disclosure

04/16/2018

         Plaintiffs:

Initial Disclosure

10/02/2017

Plaintiff's Answers to Interrogatories

03/09/2018

Plaintiff's Responses to Request to Produce

03/09/2018


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