Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Hazelett v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

May 14, 2018

STEFANY HAZELETT, Plaintiff,
v.
WAL-MART STORES, INC., a Delaware Corporation, Defendant.

          JAMES P. KEMP, ESQ. KEMP & KEMP Attorney for Plaintiff STEFANY HAZELETT

          ROGER L. GRANDGENETT II, ESQ. ETHAN D. THOMAS, ESQ. LITTLER MENDELSON, P.C. Attorneys for Defendant WAL-MART STORES, INC.

          [PROPOSED] STIPULATION AND ORDER TO TAKE DEPOSITIONS OUTSIDE CLOSE OF DISCOVERY AND TO EXTEND DISPOSITIVE MOTIONS DEADLINE

         Plaintiff, STEFANY HAZELETT and Defendant, WAL-MART STORES, INC., by and through their respective counsel of record, stipulate and agree to take the deposition of Pansy Renee Husted and the reconvened deposition of Plaintiff Stefany Hazelett on a date after the May 14, 2018 close of discovery. The parties also hereby stipulate and agree to extend the current dispositive motion deadline of June 13, 2018 up to and until July 13, 2018.

         DISCOVERY COMPLETED TO DATE

         To date, the parties have completed the following discovery:

         Plaintiff:

Plaintiffs Initial Disclosures

September 28, 2017

Plaintiffs First Supplemental Disclosures

October 9, 2017

Responses to First Set of Requests

November 21, 2017

Responses to First Set of Interrogatories

November 21, 2017

Responses to Second Set of Requests

December 8, 2017

Responses to Second Set of Interrogatories

December 8, 2017

Plaintiffs First Set of Requests

January 9, 2018

Plaintiffs First Set of Interrogatories

January9, 2018

Plaintiffs Second Supplemental Disclosures

February 28, 2018

Plaintiffs Third Supplemental Disclosures

March 7, 2018

30(b)(6) Deposition - Walmart

April 13, 2018

Plaintiffs Fourth Supplemental Disclosures

April 27, 2018

         Defendant:

Defendant's Initial Disclosures

September 29, 2017

Defendant's First Set of Requests

October 17, 2017

Defendant's First Set of Interrogatories

October 17, 2017

Defendant's Second Set of Requests

November 7, 2017

Defendant's Second Set of Interrogatories

November 7, 2017

Defendant's First Supplemental Disclosures

December 11, 2017

Responses to First Set of Requests

February 20, 2018

Responses to First Set of Interrogatories

February 20, 2018

Subpoenas to Various Medical Providers

February 23, 2018

Supplemental Responses to First Set of Requests

February 21, 2018

Defendant's Second Supplemental Disclosures

April 11, 2018

Deposition - Stefany Hazelett

April 12, 2018

Defendant's Third Supplemental Disclosures

May 1, 2018

         DISCOVERY STILL TO BE COMPLETED

Deposition - Bobbie Buist (North Carolina)

May 10, 2018

Deposition - Brett Miller (Florida)

May 11, 2018

Deposition - Stefany Hazelett (Reconvened)

June 4, 2018 (Proposed)

Deposition - Pansy Renee Husted

June 4, 2018 (Proposed)

         REASONS FOR REQUEST

         The parties have engaged in significant written discovery in this case and have met and conferred in good faith throughout the case in order to avoid court intervention in the discovery process. Additionally, the parties have conducted two key depositions in the case and are traveling this week for two additional depositions in North Carolina and Florida. While the parties have attempted to complete discovery under the parameters of the current scheduling order, the instant request, to allow depositions to be taken outside the date of the formal close of discovery and extend the dispositive motion deadline, is necessary because the depositions are critical to the parties preparation for dispositive motions/trial.

         Conducting Plaintiffs reconvened deposition on a date after the current discovery deadline is necessary because Plaintiff recently produced a series of documents in this case which are relevant to her claims (April 27, 2018). The parties have already discussed the necessity of the reconvened deposition and met and conferred regarding the parameters of the same. The parties have also discussed the deposition of Ms. Husted, a witness Defendant recently disclosed in this matter (May 1, 2018), and it is also believed to be necessary to the case. The parties have proposed dates on which these two depositions could be taken and the earliest date the schedules of all parties would permit is June 4, 2018. Accordingly, the parties ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.