United States District Court, D. Nevada
& HAUF JEFFREY L. GALLIHER, ESQ. Attorneys for Plaintiff
Dong “Kevin” Guo.
PHILLIPS, SPALLAS & ANGSTADT, LLC POOJA KUMAR, ESQ.
Attorneys for Defendant Wal-Mart Stores, Inc.
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY
DEADLINES [FIRST REQUEST]
DONG “KEVIN” GUO (hereinafter
“Plaintiff”) and Defendant WAL-MART STORES, INC.
(hereinafter “Defendant”) (collectively, the
“Parties”), by and through their respective
counsel of record, do hereby stipulate to extend the
remaining deadlines in the current Discovery Plan and
Scheduling Order in this matter for a period of sixty (60)
days for the reasons explained herein.
to Local Rule 6-1(b), the Parties hereby aver that this is
the first such discovery extension requested in this
COMPLETED TO DATE
• The Parties have conducted their FRCP 26(f) conference
and have served their respective FRCP 26(a) disclosures.
• Defendant served its FRCP 26(a) Initial Disclosures
with exhibits thereto on March 26, 2018.
• Plaintiff served her FRCP 26(a) Initial Disclosures
with exhibits thereto on April 3, 2018.
• Defendant propounded Requests for Admissions, Requests
for Production of Documents, and Interrogatories upon
• Defendant noticed he deposition of Plaintiff.
• The Parties have begun to meet and confer regarding
written discovery, authorizations, and the FRCP 35 medical
TO BE COMPLETED AND REASONS FOR EXTENSION OF
to be completed includes:
• Plaintiff's execution of HIPAA-compliant
authorizations for Defendant to obtain his medical ...