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Rosales v. Bellagio, LLC

United States District Court, D. Nevada

July 5, 2018

JORGE ROSALES, Plaintiff,
v.
BELLAGIO, LLC, a Nevada corporation; ROE Business Organizations I-X; and DOE INDIVIDUALS I-X, inclusive, Defendants.

          KEMP & KEMP JAMES P. KEMP VICTORIA L. NEAL, ATTORNEYS FOR PLAINTIFF JORGE ROSALES

          JACKSON LEWIS P.C. DEVERIE J. CHRISTENSEN, PHILLIP C. THOMPSON ATTORNEYS FOR DEFENDANT BELLAGIO, LLC

          STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)

          HON. GEORGE W. FOLWY, JR. UNITED STATES MAGISTRATE JUDGE

         Pursuant to LR 26-4, all parties hereby stipulate to extend the discovery plan and scheduling order deadlines in this action. This is the first request for an extension to the discovery plan and scheduling order in this matter.

         REASONS FOR REQUESTING EXTENSION

         On June 26, 2018, Plaintiff noticed five depositions of Defendant's current and former employees to be taken on July 17, 18, and 19, 2018. The discovery cutoff in this case is currently set for July 24, 2018. While Defendant is attempting to contact these witnesses to determine whether they are available for deposition on the dates noticed, there is a likelihood that one or more of the five witnesses will not be available on the date noticed for his or her deposition. Additionally, on June 29, 2018, Defendant issued seven subpoenas for Plaintiff's medical records. Plaintiff objected to the subpoenas and, after meeting and conferring, the parties reached an agreement whereby the documents requested can be produced as delineated in the subpoenas, but the documents are to be remained sealed for a simultaneous review. Documents outside the relevant time period and those not relevant to any claim or defense in this matter are to be removed. Moreover, documents upon which the parties cannot agree are to be removed so Plaintiff can seek the appropriate protective order(s).

         Accordingly, the parties request a 30-day extension to the discovery period to ensure that these witnesses will be available for deposition prior to the discovery cutoff.

         1. DISCOVERY COMPLETED TO DATED:

Plaintiff:
Initial disclosures to Defendant February 12, 2018
First supplemental disclosures to Defendant February 27, 2018
First set of written discovery to Defendant March 21, 2018
Responses to Defendant's written discovery May 10, 2018
Second supplemental disclosures to Defendant May ...

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