Dailey-Adams v. Albertson's LLC

Filing 17

ORDER granting 16 Stipulation; Discovery due by 11/23/2018. Motions due by 12/21/2018. Proposed Joint Pretrial Order due by 1/21/2019. Signed by Magistrate Judge George Foley, Jr on 8/16/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02602-GMN-GWF Document 16 Filed 08/15/18 Page 1 of 3

1
2
3
4
5
6
7

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
T: [phone]
F: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
Albertson’s LLC

8
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA
10
11

DANITA DAILEY-ADAMS, individually,

12
13
14
15
16

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

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

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

17
18

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

19

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

20

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

21

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

22

stipulate and agree to an extension of all remaining discovery deadlines by sixty (60) days. The

23

parties propose the following revised discovery plan:

24
25

DISCOVERY COMPLETED TO DATE
The parties conducted an Initial Disclosure Conference pursuant to LR 26-1 and Fed. R.
1

Case 2:17-cv-02602-GMN-GWF Document 16 Filed 08/15/18 Page 2 of 3

1

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

2

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

3

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

4

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

5

On March 29, 2018, Plaintiff responded to Defendant’s written discovery requests. Plaintiff’s

6

deposition was taken on May 7, 2018. The parties have made their initial expert disclosures on

7

July 25, 2018.
DISCOVERY TO BE COMPLETED

8

The parties intend to depose representatives of Defendant, other percipient witnesses,

9
10

Plaintiff’s medical providers and experts.
REASONS FOR EXTENSION TO COMPETE DISCOVERY

11

A mediation is scheduled for September 13, 2018. Thus, the parties seek a brief sixty-

12
13

day extension of the remaining discover deadlines to seek successful resolution of this case. This

14

request is made in good faith and not for the purpose of delay.
PROPOSED NEW DISCOVERY DEADLINES

15

Deadline to Amend Pleadings/Add Parties:
Currently:
March 27, 2018
Proposed:
N/A

16
17

Interim Status Report:
Currently:
July 25, 2018
Proposed:
N/A

18
19

Initial Expert Disclosure Deadline:
Currently:
July 25, 2018
Proposed:
N/A

20
21
22

Rebuttal Expert Disclosure Deadline:
Currently:
August 27, 2018
Proposed:
October 26, 2018

23
24
///
25

2

Case 2:17-cv-02602-GMN-GWF Document 16 Filed 08/15/18 Page 3 of 3

1
2
3
4
5
6

Discovery Cutoff:
Currently:
Proposed:

September 24, 2018
November 23, 2018

Deadline to File Dispositive Motions:
Currently:
October 23, 2018
Proposed:
December 21, 2018
Pre-Trial Order Deadline:
Currently:
November 22, 2018
Proposed:
January 21, 2019

7
DATED:

August 15, 2018

DATED:

August 15, 2018

8
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

9
10
11
12
13
14
15
16

ORDER

17

IT IS SO ORDERED.

18

DATED: this 16th day of of
day August, 2018.

, 2018.

19
20
21

UNITED STATES MAGISTRATE JUDGE

22
23
24
25
3