Dailey-Adams v. Albertson's LLC

Filing 14

ORDER granting 13 Stipulation; Discovery due by 9/24/2018. Motions due by 10/23/2018. Proposed Joint Pretrial Order due by 11/22/2018. Signed by Magistrate Judge George Foley, Jr on 4/18/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02602-GMN-GWF Document 13 Filed 04/17/18 Page 1 of 3

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Jack P. Burden, Esq.
Nevada State Bar No. 6918
Xiao Wen Jin, Esq.
Nevada State Bar No. 13901
BACKUS, CARRANZA & BURDEN

3050 South Durango Drive
Las Vegas, NV 89117
[phone]
[phone]
[e-mail]
[e-mail]
Attorneys for Defendant
Albertson’s LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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DANITA DAILEY-ADAMS, individually,

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Case No. 2:17-cv-02602-GMN-GWF

Plaintiffs,
STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)

vs.
ALBERTSON’S LLC; DOES I through X;
inclusive; ROE BUSINESS ENTITIES I
through X, inclusive,
Defendants.

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In accordance with Local Rules of Practice for the United States District Court for the

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District of Nevada (“LR”) 26-4, Defendant Albertson’s LLC (“Defendant”), by and through its

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counsel of record, BACKUS, CARRANZA & BURDEN, and Plaintiff Danita Dailey-Adams

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(“Plaintiff”), by and through her counsel of record, BERTOLDO BAKER CARTER & SMITH, hereby

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stipulate and agree to an extension of all remaining discovery deadlines by ninety (90) days. The

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parties propose the following revised discovery plan:

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DISCOVERY COMPLETED TO DATE
The parties conducted an Initial Disclosure Conference pursuant to LR 26-1 and Fed. R.
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Case 2:17-cv-02602-GMN-GWF Document 13 Filed 04/17/18 Page 2 of 3

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Civ. P. 26(f) on November 28, 2017. In December 2017, the parties served their initial

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disclosure of documents and the names of individuals with knowledge of the facts pertaining to

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the claims set forth in this matter pursuant to Fed. R. Civ. P. 26(a)(1). On February 28, 2018,

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Defendant propounded interrogatories and requests for production of documents upon Plaintiff.

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On March 29, 2018, Plaintiff responded to Defendant’s written discovery requests.
DISCOVERY TO BE COMPLETED

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The parties will propound additional written discovery. Deposition of Plaintiff,

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representatives of Defendant, and other percipient witnesses remain to be taken. Defendant also

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anticipates deposing Plaintiff’s medical providers. The parties are also expected to disclose and

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depose experts.
REASONS FOR EXTENSION TO COMPETE DISCOVERY

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A discovery extension is needed in this case because Plaintiff has only recently

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completed her surgery which caused delay to her deposition and the depositions of her treating

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physicians. Thus, the parties respectfully request a ninety (90) day extension of the remaining

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discovery deadlines as detailed below. This request is made in good faith and not for the purpose

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of delay.

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PROPOSED NEW DISCOVERY DEADLINES
Deadline to Amend Pleadings/Add Parties:
Currently:
March 27, 2018
Proposed:
N/A
Interim Status Report:
Currently:
April 26, 2018
Proposed:
July 25, 2018
Initial Expert Disclosure Deadline:
Currently:
April 26, 2018
Proposed:
July 25, 2018

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Rebuttal Expert Disclosure Deadline:
Currently:
May 28, 2018
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Case 2:17-cv-02602-GMN-GWF Document 13 Filed 04/17/18 Page 3 of 3

Proposed:

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August 27, 2018

Discovery Deadline:
Currently:
June 25, 2018
Proposed:
September 24, 2018
Deadline to File Dispositive Motions:
Currently:
July 25, 2018
Proposed:
October 23, 2018
Pre-Trial Order Deadline:
Currently:
August 24, 2018
Proposed:
November 22, 2018

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DATED:

April 17, 2018

DATED:

April 17, 2018

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BACKUS, CARRANZA & BURDEN

BERTOLDO BAKER CARTER & SMITH

/s/ Jack P. Burden
Jack P. Burden, Esq.
Xiao Wen Jin, Esq.
3050 South Durango Drive
Las Vegas, NV 89117
Attorneys for Defendant

/s/ Lawrence J. Smith
Lawrence J. Smith, Esq.
7408 W. Sahara Avenue
Las Vegas, NV 89117
Attorney for Plaintiff

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ORDER

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IT IS SO ORDERED.

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DATED: this 18th day of of
day April 2018

, 2018.

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UNITED STATES MAGISTRATE JUDGE

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