United States District Court, D. Nevada
& 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.
OFFICES OF MICHAEL P. BALABAN Michael P. Balaban, Attorneys
for Plaintiff Mark Lewis.
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
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.
CAUSE FOR EXTENSION TO COMPLETE DISCOVERY
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.
DISCOVERY COMPLETED 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
5. Plaintiff served written discovery to Defendants on April
6. Defendants served their responses to Plaintiff's