Hernandez v. Wal-Mart Stores, Inc. et al

Filing 23

ORDER granting 22 Stipulation; Discovery due by 4/16/2018. Motions due by 5/16/2018. Proposed Joint Pretrial Order due by 6/15/2018. Signed by Magistrate Judge Cam Ferenbach on 11/17/2017. (Copies have been distributed pursuant to the NEF - JM)

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LEONARD T. FINK, ESQ.
Nevada Bar No. 6296
NAKESHA S. DUNCAN, ESQ.
Nevada Bar No. 11556
SPRINGEL & FINK LLP
10655 Park Run Drive, Suite 275
Las Vegas, Nevada 89144
Telephone: [phone]
Facsimile: [phone]
E-Mail:
[e-mail]
[e-mail]
Attorneys for Defendants,
SECURITAS SECURITY SERVICES USA, INC.
and WAL-MART STORES, INC. d/b/a
WALMART SUPERCENTER #3473

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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***
EDDIE HERNANDEZ,
Plaintiff,

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Case No.: 2:16-cv-02917

vs.

STIPULATION TO EXTEND DISCOVERY

WAL-MART STORES, INC. d/b/a WALMART
SUPERCENTER #3473; SECURITAS SECURITY
SERVICES USA, INC.; UNKNOWN SECURITY
GUARD; DOES 1-V, inclusive; ROE BUSINESS
ENTITIES I-V, inclusive,

[THIRD REQUEST]

Defendants.

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The parties, by and through their respective, undersigned, attorneys of record, hereby submits
this Stipulation and Order to Extend Discovery Deadlines, as detailed below.

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Pursuant to LR IA 6-1, this is the third stipulation for extension of time for discovery submitted

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by the parties. Pursuant to LR II 26-4, the parties agree to extend the remaining discovery deadlines to

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allow each party to complete the remaining, necessary discovery. As the parties wish to conduct

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mediation, good cause exists to allow the parties additional time to conduct the remaining discovery,

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including depositions.

{N0379479;1}

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A. Discovery Completed

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The following discovery has been completed:

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1. Plaintiff and Defendants have exchanged FRCP 26 disclosures of witnesses and documents,

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and supplements thereto.

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2. Defendant SECURITAS SECURITY SERVICES USA, INC. has propounded written

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discovery upon Plaintiff.

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3. Plaintiff has propounded written discovery upon Defendants.

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4. Defendants have responded to Plaintiff’s written discovery.

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5. Plaintiff has responses to Defendants’ written discovery.

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6. An independent medical examination of Plaintiff has been completed.

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7. Defendants have disclosed their initial expert witness.

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B. Discovery that Remains to Be Completed

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1. Designation of Plaintiff’s initial expert witnesses.

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2. Designation of rebuttal expert witnesses.

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3. Deposition of Plaintiff.

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4. Deposition of Defendants’ FRCP 30(b)(6) witnesses.

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5. Depositions of Plaintiff’s treating physicians, if necessary.

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6. Depositions of experts.

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7. Additional written discovery, if necessary.

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C. Reason Why Remaining Discovery Was Not Completed

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Now, that the majority of discovery has been completed, the parties wish to engage in mediation,

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in an attempt to settle this matter. Pursuant to the parties’ and their clients’ schedules, they are working

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to schedule mediation in January 2018. This third extension will ensure that the parties have time to

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disclosure appropriate experts and schedule and take necessary depositions, prior to trial. It will also

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ensure that the parties do not waste unnecessary litigation money on expert reports and/or depositions, if

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this matter is able to be settled at mediation. Based on the foregoing, good cause exists to extend the

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remaining discovery deadlines.

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{N0379479;1}

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D. Proposed Schedule
The parties propose the following extended schedule:

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Discovery to be Completed

Current Deadlines

Proposed Deadlines

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Initial expert disclosures

October 16, 2017

February 16, 2017 8

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Rebuttal expert disclosures

November 15, 2017

March 16, 2017 8

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Close of Discovery

December 17, 2017

April 16, 2018

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Dispositive motions

January 16, 2017

May 16, 2018

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Pre-Trial Order

February 15, 2018

June 15, 2018

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IT IS SO STIPULATED.
DATED this 16th day of November, 2017.

DATED this 16th day of November, 2017.

SPRINGEL & FINK LLP

GAZDA & TADAYON

/s/ Nakesha S. Duncan, Esq.
_________________________________
LEONARD T. FINK, ESQ.
Nevada Bar No. 6296
NAKESHA S. DUNCAN, ESQ.
Nevada Bar No. 11556
10655 Park Run Drive, Suite 275
Las Vegas, Nevada 89144

/s/ Lewis Gazda, Esq.
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LEWIS GAZDA, ESQ.
Nevada Bar No. 4269
AFSHIN TADAYON, ESQ.
Nevada Bar No. 6517
2600 South Rainbow Blvd., Suite 200
Las Vegas, NV 89146

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ORDER

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Based on the parties’ stipulation [ ] and good cause appearing, IT IS HEREBY ORDERED that
the remaining discovery deadlines are extended pursuant to the parties’ stipulation.
November
17th
Dates this ___ day of ______________, 2017.
___________________________________
UNITED STATES MAGISTRATE JUDGE

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If dispositive motions are filed, the deadline
for filing the joint pretrial order will be suspended until 30 days after
decision on the dispositive motions or further court order.

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{N0379479;1}

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