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Sanchez v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

July 26, 2018

MANUEL SANCHEZ, Plaintiff,
v.
WAL-MART STORES, INC.; DOES 1-20 and ROE BUSINESS ENTITIES 1-20, inclusive, Defendants.

          RAMZY PAUL LADAH, ESQ. Attorneys for Plaintiff Manuel Sanchez

          RYAN KERBOW Attorneys for Defendant Wal-Mart Stores, Inc.

          STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES [SECOND REQUEST]

         Plaintiff Plaintiff MANUEL SANCHEZ (“Plaintiff”) and Defendant WAL-MART STORES, INC. (“Walmart”), by and through their respective counsel of record, do hereby stipulate to extend the discovery deadlines in the present case for a period of 60 days Pursuant to Local Rule IA 6-1 and Local Rule 26-4.

         Pursuant to Local Rule IA 6-1(a), the parties hereby aver that this is the second such discovery extension requested in this matter.

         DISCOVERY COMPLETED TO DATE

         • The parties have conducted an FRCP 26(f) conference and have served their respective FRCP 26(a) disclosures;

         • Walmart has served written discovery to Plaintiff;

         • Plaintiff has Answered Discovery Propounded by Defendant Walmart

         DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF DISCOVERY

         Discovery to be completed includes:

         • Written Discovery to Defendant Walmart

         • Disclosure of expert witnesses;

         • Walmart will depose Plaintiff;

         • Plaintiff will depose Person Most Knowledge 30(b)(6) ...


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