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Sandoval v. Albertsons LLC

United States District Court, D. Nevada

May 18, 2018

SILVIA SANDOVAL, Plaintiff,
v.
ALBERTSONS, LLC d/b/a ALBERTSONS; DOES I - X, and ROE CORPORATIONS I - X, inclusive, Defendants.

          LEW BRANDON, JR., ESQ. Nevada Bar No. 5880 KRIS D. KLINGENSMITH, ESQ. Nevada Bar No. 13904 MORAN BRANDON BENDAVID MORAN Attorneys for Defendant, ALBERTSONS, LLC

          ALEX J. DE CASTROVERDE, ESQ. Nevada Bar No. 6950 ORLANDO DE CASTROVERDE, ESQ. Nevada Bar No. 7320 DAVID MENOCAL, ESQ. Nevada Bar No. 13191 KIMBERLY VALENTIN, ESQ. Nevada Bar No. 12509 DE CASTROVERDE LAW GROUP Attorneys for Plaintiff, SILVIA SANDOVAL

          AMENDED STIPULATION AND ORDER FOR EXTENSION/MODIFICATION OF DISCOVERY PLAN AND SCHEDULING ORDER(FOURTH REQUEST)

         COMES NOW Defendant, ALBERTSONS, LLC., by and through its undersigned attorneys, LEW BRANDON, JR., ESQ. and KRIS D. KLINGENSMITH, ESQ. of MORAN BRANDON BENDAVID MORAN, and Plaintiff, by and through her attorneys, ALEX J. DE CASTROVERDE, ESQ. and ORLANDO DE CASTROVERDE, ESQ., of DE CASTROVERDE LAW GROUP, submit to the Court the following Stipulation and Order for Extension/Modification of the Discovery Plan and Scheduling Order (Fourth Request) pursuant to LR IA 6-1, LR 26-4 (a) and Court Order Document No. 26.

         I. Local Rule 6 -1

         Under LR IA 6-1(a) every stipulation to extend time must inform the court of any previous extensions granted and state the reason for the extension requested.

         A. The Requirement of Local Rule 6-1 Are Satisfied

         This is the fourth request for extension filed by the parties. This extension is requested to allow for the deposition of Plaintiff's experts, Dr. Kaplan and Mr. Jennings, to be conducted.

         II. Local Rule 26-4(a)

         Under LR 26-4 (a) a statement specifying the Discovery completed:

         The parties have nearly completed the discovery phase in this matter. Both sides have sent and received written discovery in the form of Requests for Production, Requests for Admissions and Interrogatories. The Plaintiff and the percipient witnesses identified in her disclosures have been deposed by Defendant. The Plaintiff has deposed Defendant's FRCP 30(b)(6) witness and three of its employees/former employees. Experts have been disclosed by both parties.

         III. Local Rule 26-4(b)

         Under LR 26-4(b) a specific description of the Discovery that remains to be completed: The remaining Discovery to be completed includes the depositions of Plaintiff's experts.

         IV. Local Rule 26-4(c)

         Under LR 26-4(c) the reasons why Discovery remaining was not completed within the ...


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