United States District Court, D. Nevada
& 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)
GEORGE W. FOLWY, JR. UNITED STATES MAGISTRATE JUDGE
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.
FOR REQUESTING EXTENSION
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).
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.
DISCOVERY COMPLETED TO DATED:
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 ...