United States District Court, D. Nevada
LERNER INJURY ATTORNEYS Gregory G. Gordon, Esq. Attorney for
PHILLIPS, SPALLAS & ANGSTADT, LLC Timothy D. Kuhls Robert
K. Phillips, Esq. Attorneys for Defendant
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DISCOVERY DEADLINES [FIRST REQUEST]
to LR 6-1 and LR 26-4, the parties, by and through their
respective counsel of record, hereby stipulate and request
that this Court extend discovery in the above-captioned case
ninety (90) days for the reasons explained herein.
to Local Rule 6-1(b), the parties hereby aver that this is
the first such discovey extension requested in this matter.
July 1, 2019, this action was commenced by filing of a
Complaint in Clark County District Court.
July 22, 2019, Defendant answered the Complaint
July 24, 2019, Counsel for Defendant removed the case from
State Court to Federal Court.
parties have conducted an FRCP 26(f) conference and have
served their respective FRCP 26(a) disclosures.
Defendant has served upon Plaintiff one set of Requests to
Produce, one set of Interrogatories and one set of Requests
for Admissions. Plaintiff has responded to each.;
Plaintiff has served upon Defendant one set of Requests for
Production, one set of Interrogatories, and one set of
Request for Admissions. Defendant has responded to each.
Defendant has taken the deposition of Plaintiff.
THAT REMAINS TO BE COMPLETED:
Deposition of Rule 30(b)(6) witness of Defendant. Plaintiff
is in the process of presenting categories of examination
with respect to same so that Defendant has ample time to
identify a proper ...