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Lewis v. R&L Carriers, Inc.

United States District Court, D. Nevada

July 16, 2018

Mark Lewis, Plaintiff,
v.
R&L CARRIERS, Inc., an Ohio Corporation R&L CARRIERS SHARED SERVICES, LLC, an Ohio Limited Liability Company, Defendants.

          SNELL & WILMER L.L.P. Paul Swenson Prior, Karl O. Riley, Anthony C. White, Admitted Pro Hac Vice THOMPSON HINE LLP Attorneys for Defendants R&L Carriers, Inc. and R&L Carriers Shared Services, LLC.

          LAW OFFICES OF MICHAEL P. BALABAN Michael P. Balaban, Attorneys for Plaintiff Mark Lewis.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)

         Plaintiff Mark Lewis and Defendants R&L Carriers, Inc. and R&L Carriers Shared Services, LLC, by and through their respective counsel (collectively, the “Parties”), for good cause shown, hereby stipulate and agree to extend all discovery deadlines in this matter by 60 days. This request complies with Local Rule (“LR”) 6-1, 6-3, 7-1, and 26-4, and is based on good cause because the litigation of this matter will be best served by the proposed extension. This is the Parties' second extension request.

         I. GOOD CAUSE FOR EXTENSION TO COMPLETE DISCOVERY

         Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Rule 6-1, there exists good cause to grant this extension to allow the parties to coordinate depositions with Plaintiff's treating physicians. Specifically, the parties have tried to coordinate dates to take the depositions of several of Plaintiff's treating physicians; however, the schedules are not compatible, until after the current August 29 discovery cut-off. Accordingly, the parties jointly believe that good cause exists to extend the discovery deadlines for sixty (60) days.

         II. DISCOVERY COMPLETED TO DATE

         To date the Parties have completed the following discovery:

1. Defendants served their initial disclosures on or about January 23, 2018.
2. Defendants served written discovery to Plaintiff on February 8, 2018.
3. Plaintiff served his responses to Defendants' written discovery on or about April 4, 2018.
4. Plaintiff served his initial disclosures on or about April 4, 2018.
5. Plaintiff served written discovery to Defendants on April 4, 2018.
6. Defendants served their responses to Plaintiff's written ...

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