United States District Court, D. Nevada
LAW FIRM DAVID A. TANNER, ESQ. Attorney for Plaintiff TERESA
LEVENSON, P.A. JERRY S. BUSBY, ESQ. Attorneys for Defendant
SMITH'S FOOD & DRUG CENTERS, INC.
STIPULATION AND ORDER TO EXTEND DISCOVERY (THIRD
The parties can show good cause for the delay in filing the
stipulation is submitted in accordance with LR II 26-4 as it
is being filed after the expiration date of the
Initial-Expert Disclosure Deadline of June 22, 2018.
requirements to show good cause under LR 26-4 are the same as
that for the modification of the scheduling order under
Fed.R.Civ.P. 16(b). "The good cause standard primarily
considers the diligence of the party or parties seeking the
extension. If the party seeking the modification 'was not
diligent, the inquiry should end' and the motion should
not be granted." In assessing whether good cause exists for
an extension of time to complete discovery, die" Court
looks to the quality and diligence of prior discovery
efforts. It must weigh those efforts against the'
what,' 'why,' 'when,' and 'how'
DISCOVERY COMPLETED TO DATE
March 16, 2017, Plaintiff filed her Complaint in the Eighth
Judicial District Court.
May 18, 2017, Plaintiff served the Complaint on Defendant.
June 7, 2017, Defendant filed its Answer to Plaintiffs
September 1, 2017, the parties conducted the NRCP 16.1 Early
Case Conference in the State Court case.
October 19, 2017, Plaintiff propounded written discovery upon
October 23, 2017, Defendant filed its Petition for Removal.
November 30, 2017, the parties submitted a Stipulated
Discovery Plan and Scheduling ...