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Guo v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

May 15, 2018

DONG “KEVIN” GUO, Plaintiff,
v.
WAL-MART STORES, INC., a foreign corporation; DOE WORKER, an individual; DOES 1 through 10, inclusive; and ROE CORPORATIONS 1 through 10, Inclusive, Defendants.

          GANZ & 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]

         Plaintiff 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.

         Pursuant to Local Rule 6-1(b), the Parties hereby aver that this is the first such discovery extension requested in this matter.

         DISCOVERY 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 Plaintiff.
• Defendant noticed he deposition of Plaintiff.
• The Parties have begun to meet and confer regarding written discovery, authorizations, and the FRCP 35 medical examination.

         DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF DISCOVERY

         Discovery to be completed includes:

• Plaintiff's execution of HIPAA-compliant authorizations for Defendant to obtain his medical ...

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