Hedman v. Albertsons LLC

Filing 14

ORDER that the 13 Stipulation to Extend Discovery Deadline Dates (First Request) is approved except for the deadline to amend. Discovery due by 5/29/2018. Motions due by 6/29/2018. Proposed Joint Pretrial Order due by 7/30/2018. Signed by Magistrate Judge Nancy J. Koppe on 1/10/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02559-JAD-NJK Document 13 Filed 01/09/18 Page 1 of 5

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BRIAN D. NETTLES, ESQ.
Nevada Bar No. 7462
WILLIAM R. KILLIP, JR., ESQ.
Nevada Bar No. 3660
JENNIFER A. PETERSON, ESQ
Nevada Bar No. 11242
NETTLES LAW FIRM
1389 Galleria Drive, Suite 200
Henderson, Nevada 89014
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff

1389 Galleria Drive Suite 200
Henderson, NV 89014
[phone] / [phone] (fax)

NETTLES LAW FIRM

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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YVONN HEDMAN, an individual,

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CASE NO. 2:17-cv-02559-JAD-NJK

Plaintiff,
vs.
ALBERTSON’S, LLC, a Foreign Limited
Liability Company; DOE INDIVIDUALS 1
through 10; ROE CORPORATIONS 11
through 20; and ABC LIMITED LIABILITY
COMPANIES 21 through 30, inclusive,

STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINE
DATES (FIRST REQUEST)

Defendants.

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COME NOW, Plaintiff YVONN HEDMAN, by and through her attorneys BRIAN D.

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NETTLES, ESQ., and WILLIAM R. KILLIP, JR., ESQ., and JENNIFER A. PETERSON, ESQ.,

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of the NETTLES LAW FIRM; and Defendant ALBERTSON’S, LLC, by and through its

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attorneys LEW BRANDON, JR., ESQ., and MATTHEW WHITTAKER, ESQ., of MORAN

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BRANDON BENDAVID MORAN, and hereby submit the following Stipulation pursuant to

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Local Rule 26-4. Based upon the following, the Parties request this Court extend all discovery

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Case 2:17-cv-02559-JAD-NJK Document 13 Filed 01/09/18 Page 2 of 5

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deadlines by sixty (60) days. This request is made in good faith and not to unduly delay the

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proceedings.

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I.

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Local Rule 6-1
Under LR 6-1(b) every stipulation to extend time must inform the court of any previous

extensions granted and state the reason for the extension requested.

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a.

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This is the first request for extension filed by the parties. The parties are seeking this

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extension in order to complete additional discovery that could not be completed during the time

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allotted.

1389 Galleria Drive Suite 200
Henderson, NV 89014
[phone] / [phone] (fax)

NETTLES LAW FIRM

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II.

The Requirement of Local Rule 6-1 Are Satisfied

Local Rule 26-4(a)

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Under LR 26-4(a) a statement specifying the Discovery completed:

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a. Initial disclosures have been exchanged between all parties;

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b. Written discovery has been expedited;

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c. Defendant has scheduled the Custodian of Records Depositions for January 5, 2018,

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at 8:00 a.m. for the following treating providers:

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1. St. Rose Dominican Hospital – Rose De Lima Campus;

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2. Fremont Emergency Services;

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3. Radiology Associates of Nevada;

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4. Advanced Pain Management;

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5. ATI Physical Therapy;

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6. Valley View Surgery Center;

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7. Steinberg Diagnostic Medical Imaging Centers;

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8. United Toxicology, LLC

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9. Next Step Medical;

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10. Advanced Orthopedics and Sport Medicine; and

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11. Parkway Surgery Center.

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…

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…

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Case 2:17-cv-02559-JAD-NJK Document 13 Filed 01/09/18 Page 3 of 5

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d. Defendant has scheduled Plaintiff’s Deposition for January 17, 2018;

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e. Plaintiff has scheduled the deposition of Maria Ramirez, Defendant’s employee, for

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February 6, 2018 at 10:00 a.m.; and

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f. Plaintiff has scheduled the deposition of witness Marsha Prince for February 6, 2018,

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at 1:00 p.m.
III.

Local Rule 26-4(b)

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Under LR 26-4(b) a specific description of the Discovery that remains to be completed:

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a. The remaining Discovery to be completed is Plaintiff’s deposition, FRCP 30(b)(6)

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depositions of Defendant, Deposition of Defendant’s employees, depositions of

1389 Galleria Drive Suite 200
Henderson, NV 89014
[phone] / [phone] (fax)

NETTLES LAW FIRM

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treating physicians, and disclosure and depositions of the experts.
IV.

Local Rule 26-4(c)

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Under LR 26-4(c) the reasons why Discovery remaining was not completed within the

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time limits set by the Discovery Plan:

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a. Due to various scheduling conflicts, it has been impossible to conduct depositions

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which must be completed prior to the disclosure of experts. Additionally, Plaintiff’s

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counsel has a trail in District Court, scheduled for January 22, 2018 (Zavala vs.

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Quesada; Case No. A-14-699223-C), which will limit the parties’ ability to

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reschedule depositions prior to the expert disclosure deadline.

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V.

Local Rule 26-4(d)

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Under LR 26-4(d) a proposed schedule for completing all remaining Discovery:

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a. Discovery cutoff dates:

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Current date:

March 30, 2018

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Proposed date:

May 29, 2018

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b. Amending the Pleadings and Adding Parties:

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Current date:

December 29, 2017

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Proposed date:

DENIED. See
Local Rule 26-4.

February 27, 2018

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…

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…

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Case 2:17-cv-02559-JAD-NJK Document 13 Filed 01/09/18 Page 4 of 5

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c. Disclosures of Experts:

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i. Initial expert disclosures:

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Current date:

January 29, 2018

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Proposed date:

March 30, 2018

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ii. Rebuttal expert disclosures:

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Current date:

February 28, 2018

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Proposed date:

April 30, 2018

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d. Interim Status Report:

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1389 Galleria Drive Suite 200
Henderson, NV 89014
[phone] / [phone] (fax)

NETTLES LAW FIRM

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Current date:

January 29, 2018

Proposed date:

March 30, 2018

e. Dispositive Motions:

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Current date:

April 30, 2018

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Proposed date:

June 29, 2018

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f. Joint Pre-Trial Order:

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Current date:

May 30, 2018

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Proposed date:

July 30, 2018

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Therefore, good cause existing, counsel jointly request that this Honorable Court allow
them the above proposed extended Discovery dates.

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DATED this 9th day of January, 2018.

DATED this 9th day of January, 2018.

NETTLES LAW FIRM

MORAN BRANDON BENDAVID MORAN

By: /s/ Jennifer A. Peterson
JENNIFER A. PETERSON, ESQ.
Nevada Bar No. 11242
1389 Galleria Drive, Suite 200
Henderson, Nevada 89014
Attorney for Plaintiff

By: /s/ Matthew Whittaker
MATTHEW WHITTAKER, ESQ.
Nevada Bar No. 13281
630 South Fourth Street
Las Vegas, Nevada 89101
Attorney for Defendant

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ORDER
Upon stipulation of counsel and good cause appearing therefore:

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Case 2:17-cv-02559-JAD-NJK Document 13 Filed 01/09/18 Page 5 of 5

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IT IS HERBY ORDERED that the Stipulation and Order to Extend Discovery
Deadline Dates (First Request) is hereby approved.,, except as to the deadline to amend.
except
January 10
DATED this _____ day of ____________________, 2018.

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________________________________________
UNITED STATES MAGISTRATE JUDGE

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1389 Galleria Drive Suite 200
Henderson, NV 89014
[phone] / [phone] (fax)

NETTLES LAW FIRM

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Respectfully submitted by:
NETTLES LAW FIRM
By: /s/ Jennifer A. Peterson
JENNIFER A. PETERSON, ESQ.
Nevada Bar No. 11242
1389 Galleria Drive, Suite 200
Henderson, Nevada 89014
Attorney for Plaintiff

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