Abdullah v. Wal-Mart Stores, Inc.

Filing 16

ORDER granting 15 Stipulation; Discovery due by 5/21/2018. Motions due by 6/19/2018. Proposed Joint Pretrial Order due by 7/17/2018. Signed by Magistrate Judge Cam Ferenbach on 12/18/2017. (Copies have been distributed pursuant to the NEF - JM)

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ROBERT K. PHILLIPS
Nevada Bar No. 11441
BETSY C. JEFFERIS
Nevada Bar No. 12980
PHILLIPS, SPALLAS & ANGSTADT LLC
504 South Ninth Street
Las Vegas, Nevada 89101
[phone]
[phone] (Fax)
[e-mail]
[e-mail]
Attorneys for Defendant
Wal-Mart Stores, Inc.
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Case No.: 2:17-cv-02647-GMN-VCF
SADIYYAH ABDULLAH,

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SECOND AMENDED STIPULATION
AND ORDER TO EXTEND DISCOVERY
DEADLINES

Plaintiff,

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v.

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WAL-MART STORES INC.; DOES I-X,
inclusive, and ROE CORPORATIONS I-X,
inclusive,

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[FIRST REQUEST]

Defendants.

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Plaintiff SADIYYAH ABDULLAH (hereinafter “Plaintiff”) and Defendant WAL-MART
STORES, INC. (hereinafter “WALMART” or “Defendant”), by and through their respective counsel
of record, do hereby stipulate to extend the remaining deadlines in the current scheduling order and
discovery plan in this matter for a period of sixty (60) days for the reasons explained herein.

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Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the first such discovery
extension requested in this matter.
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DISCOVERY COMPLETED TO DATE
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The parties have conducted an FRCP 26(f) conference and have served their respective FRCP
26(a) disclosures;

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Plaintiff has served upon Defendant one sets of Requests for Production, one set of

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Interrogatories and one set of Requests for Admissions. Defendant is in the process of

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responding to said Requests.
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Defendant has served upon Plaintiff one set of Requests for Production, one set of

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Interrogatories and one set of Requests for Admissions. Plaintiff has submitted timely

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responses to first written discovery;

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DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF DISCOVERY

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Discovery to be completed includes:

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Plaintiff’s IME with Defendant’s expert physicians;

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Additional written discovery (if necessary);

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Depositions of fact witnesses;

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Depositions of Plaintiff’s treating physicians;

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Depositions of expert witnesses and rebuttal expert witnesses;

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Defendant’s 30(b)(6) witness deposition;

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Inspection of the subject premises (if necessary).

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The parties aver, pursuant to Local Rule 6-1, that good cause exists for their requested extension of

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current discovery because Defendant’s 30(b)(6) witness will be taken after January 3, 2017, as Walmart is

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currently in its holiday blackout period. Further, the parties anticipate a greater likelihood that they will

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be able to negotiate a resolution of this case prior to incurring fees and costs for pre- trial preparation.

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[PROPOSED] NEW DISCOVERY DEADLINES

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Expert Disclosure Deadline .

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March 20, 2018

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Joint Interim Status Report .

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March 20, 2018

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Rebuttal Expert Disclosure Deadline

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April 20, 2018

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Discovery Cut-Off Date

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May 21, 2018

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Dispositive Motion Deadline

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June 19, 2018

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Proposed Joint Pre-Trial Order

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July 17, 2018

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If this extension is granted, all anticipated additional discovery should be concluded within the

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stipulated extended deadline. The parties aver that this request for extension of discovery deadlines is

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made by the parties in good faith and not for the purpose of delay.

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DATED this 15TH day of December, 2017.

DATED this 15th day of December, 2017.

/s/ David M. Menocal
____________________________
DAVID M. MENOCAL, ESQ.
Nevada Bar No. 13191
DECASTROVERDE LAW GROUP
1149 S. Maryland Pkwy
Las Vegas, Nevada 89104

/s/ Betsy C. Jefferis
______________________________
BETSY C. JEFFERIS, ESQ.
Nevada Bar No. 12980
PHILLIPS SPALLAS & ANGSTADT LLC
504 South Ninth Street
Las Vegas, Nevada 89101

Attorneys for Plaintiff
Sadiyyah Abdullah

Attorneys for Defendant
Wal-Mart Store, Inc.

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IT IS SO ORDERED:
If dispositive motions are filed, the _____________________________________
deadline for filing the joint pretrial UNITED STATES MAGISTRATE JUDGE
order will be suspended until 30
days after decision on the
12-18-2017
DATED:_____________________________
dispositive motions or further
court order.

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CERTIFICATE OF SERVICE

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Pursuant to FRCP Rule 5, I hereby certify that I am an employee of the law firm PHILLIPS,
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SPALLAS & ANGSTADT, LLC, and that on this 15th day of December, 2017, I electronically served

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a copy of SECOND AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY
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DEADLINES [FIRST REQUEST] as follows:
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By facsimile addressed to the following counsel of record, at the address listed below;
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By placing same to be deposited for mailing in the United States Mail, in a sealed envelope
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upon which first class postage was prepaid in Las Vegas, Nevada;
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By Hand Delivery (ROC); and/or
By Electronic Service through CM/ECF to:
ATTORNEY OF RECORD
Alex J. De Castroverde
Nevada Bar No. 6950
Orlando De Castroverde
Nevada Bar No. 7320
DE CASTROVERDE LAW GROUP
1149 S. Maryland Pkwy
Las Vegas, NV 89104

TELEPHONE/FAX
Phone [phone]
Fax [phone]

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/s/ Betsy C. Jefferis
An Employee of PHILLIPS, SPALLAS & ANGSTADT LLC

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PARTY
Plaintiff