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Torres v. Bodega Latina Corp.

United States District Court, D. Nevada

July 26, 2018

ISABEL TORRES, individually Plaintiff,
v.
BODEGA LATINA CORPORATION, d/b/a EL SUPER, a Foreign Corporation, DOES 1-20 and ROE BUSINESS ENTITIES 1-20, inclusive, Defendants.

          MICHAEL C. MILLS, ESQ. Nevada Bar No. 003534 BAUMAN LOEWE WITT & MAXWELL Attorneys for Defendant, Bodega Latina Corporation, dba El Super

          RICHARD HARRIS LAW FIRM ELAINE H. MARZOLA, ESQ. Nevada State Bar No. 012442 Attorneys for Plaintiff, Isabel Torres

          STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN DEADLINES (SECOND REQUEST)

         Plaintiff Isabel Torres and Defendant Bodega Latina Corporation, by and through their respective counsel, and pursuant to Local Rule 26-4, stipulate to modify their discovery plan as follows:

         1. Plaintiff filed her Complaint on October 18, 2017 in the Eighth Judicial District Court, Case No. A-17-763267-C. Defendant filed their Answer and Jury Demand on November 9, 2017. This case was removed to the United States District Court on January 3, 2018.

         2. The parties held their F.R.C.P. 26 conference on January 10, 2018 and filed their Stipulated Discovery Plan and Scheduling Order on January 16, 2018. In this original plan, the parties agreed to the following dates:

Last Day to Amend Pleadings: 04/18/2018
Expert Disclosure Deadline: 05/18/2018
Interim Status Report Deadline: 05/18/2018
Rebuttal Expert Disclosure: 06/18/2018
Discovery Cut-Off: 07/17/2018
Dispositive Motions Deadline: 08/17/2018
Pre-Trial Order: 09/17/2018

         The initial discovery plan was signed by United States Magistrate Cam Ferenbach, January 17, 2018.

         3. The Parties filed a Stipulation and Order to Extend Discovery and deadlines [First Request] on April 19, 2018. In this plan, the parties agreed to the following dates:

Last Day to Amend Pleadings: ...

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