United States District Court, D. Nevada
K. PHILLIPS, ESQ. Nevada Bar No. 11441 TIMOTHY D. KUHLS, ESQ.
Nevada Bar No. 13362 PHILLIPS, SPALLAS & ANGSTADT LLC
Attorneys for Defendant Walmart Stores, Inc.
MICHAEL C. KANE, ESQ. Nevada Bar No. 10096 BRADLEY J. MYERS
Nevada Bar No. 8857 JOEL S. HENGSTLER, ESQ. Nevada Bar No.
11597 Attorneys for Plaintiff Mark Ho
STIPULATION AND ORDER TO CONDUCT CERTAIN DISCOVERY
OUTSIDE THE DISCOVERY PERIOD [FIRST REQUEST]
MARK HO (hereinafter “Plaintiff”), and Defendant,
WAL-MART STORES, INC. (hereinafter “Defendant” or
“Walmart”), by and through their respective
counsel of record, do hereby stipulate to conduct certain
discovery outside the discovery period. Specifically, the
parties stipulate that Defendant shall take the
depositions of fact witnesses, ROBERT CUI and SUNSEARAE CUI
on May 13th, 2019. If said witnesses are not available on
said date, the depositions will be completed within one week
to Local Rule 2.25, the parties hereby aver that this is the
first such discovery request to take certain
depositions outside the discovery period.
COMPLETED TO DATE
The parties conducted the FRCP 26(f) conference on July 11,
2018. As to serving their respective initial FRCP 26(a)
disclosures and supplements thereto, please see the
o Plaintiff served his initial disclosure statement on August
o Plaintiff served his first supplemental disclosure
statement on September 21st, 2018;
o Plaintiff served his second supplemental disclosure
statement on November 1st, 2018;
o Plaintiff served his third supplemental disclosure
statement on December 10th, 2018;
o Plaintiff served his fourth supplemental disclosure
statement on December 21st, 2018;
o Plaintiff served his fifth supplemental disclosure
statement on January 30th, 2019;
o Plaintiff served his sixth supplemental disclosure
statement on February 28th, 2019;
o Plaintiff served his seventh supplemental disclosure
statement on ...