United States District Court, D. Nevada
PAUL LADAH, ESQ. Attorneys for Plaintiff Manuel Sanchez
KERBOW Attorneys for Defendant Wal-Mart Stores, Inc.
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY
DEADLINES [SECOND REQUEST]
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.
to Local Rule IA 6-1(a), the parties hereby aver that this is
the second such discovery extension requested in
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
TO BE COMPLETED AND REASONS FOR EXTENSION OF
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) ...