Aguilar-Giles v. Cardenas Markets, Inc.

Filing 13

ORDER granting 12 Motion to Extend Discovery. Discovery due by 8/17/2018. Motions due by 9/17/2018. Proposed Joint Pretrial Order due by 10/12/2018. Signed by Magistrate Judge Carl W. Hoffman on 4/2/2018. (Copies have been distributed pursuant to the NEF - MMM)

1
2
3
4
5

MICHAEL P. LOWRY, ESQ.
Nevada Bar No. 10666
E-mail: [e-mail]
WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101-6014
Tel: [phone]/Fax: [phone]
Attorneys for Cardenas Markets, Inc.

6

UNITED STATES DISTRICT COURT

7

DISTRICT OF NEVADA

8

MARLENE AGUILAR-GILES, an individual, Case No.: 2:17-cv-3096

9

Plaintiff,
Stipulation and Order to Extend Discovery
(First Request)

10

vs.

11

CARDENAS MARKETS, INC., a foreign
corporation; DOES I through X; and ROE
BUSINESS ENTITIES I through X, inclusive,

12
13

Defendants.

14
15

The parties stipulate to extend discovery and request an amended scheduling order.
I.

LR 6-1 is satisfied.

16

This is the parties’ first request for extension. The principle purpose is due to Plaintiff’s

17

recommended future medical treatment. Cardenas requires additional time to assess the medical

18

treatment Plaintiff recently disclosed so as to prepare for medical expert disclosures. The

19

deadlines at issue have not yet expired.

20

This request is submitted within 21 days of the deadlines it seeks to extend. However the

21

Cardenas did not receive the formal report from Plaintiff’s treating physician specifically

22

recommending future treatment until shortly after it was served on March 23. Plaintiff’s

23

disclosure was timely, but Cardenas simply requires additional time to assess it.

24

II.

LR 26-4 is satisfied

25

Both parties have served Rule 26(a)(1) disclosures and have responded to written

26

discovery. No depositions have yet been taken. The remaining discovery includes depositions

27

of witnesses and expert disclosures. This is a personal injury lawsuit and medical experts are

28

necessary for both parties.
Page 1

1

III.

Current and proposed schedule for completing discovery.

2
3
4
5
6
7
8
9
10
11
12
13
14

Current Schedule
March 19, 2018

Proposed Schedule
Closed

April 18, 2018

June 18, 2018

May 18, 2018
June 18, 2018
July 17, 2018
August 16, 2018

Motions to add parties and
amend pleadings
Initial expert disclosures
and interim status report
Rebuttal expert disclosures
Close of Discovery
Dispositive motions
Pre-Trial Order

July 18, 2018
August 17, 2018
September 17, 2018
October 12, 2018

DATED this 30th day of March, 2018.

DATED this 30th day of March, 2018.

WILSON ELSER MOSKOWITZ
EDELMAN & DICKER LLP

HUTCHINGS LAW GROUP, LLC

/s/ Michael P. Lowry
Michael P. Lowry, Esq.
Nevada Bar No. 10666
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101-6014
Tel: [phone]/Fax: [phone]
Attorneys for Cardenas Markets, Inc.

/s/ Mark H. Hutchings
Mark H. Hutchings, Esq.
Nevada Bar No.12783
552 E. Charleston Blvd.
Las Vegas, Nevada 89104
Tel: [phone]/Fax: [phone]
Attorneys Marlene Aguilar-Giles

IT IS SO ORDERED.

15
16
17

UNITED STATES MAGISTRATE JUDGE

18

DATED: April 2, 2018

19
20
21
22
23
24
25
26
27
28
Page 2

1

CERTIFICATE OF SERVICE

2

Pursuant to FRCP 5, I certify that I am an employee of Wilson Elser Moskowitz

3

Edelman & Dicker LLP, and that on March 30, 2018, I served Stipulation and Order to

4

Extend Discovery (First Request) as follows:

5
6
7
8
9
10
11
12
13
14
15

by placing same to be deposited for mailing in the United States Mail, in a sealed
envelope upon which first class postage was prepaid in Las Vegas, Nevada;
via electronic means by operation of the Court’s electronic filing system, upon
each party in this case who is registered as an electronic case filing user with the
Clerk;
Mark H. Hutchings, Esq.
HUTCHINGS LAW GROUP, LLC
552 E. Charleston Blvd.
Las Vegas, Nevada 89104
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff Marlene Aguilar-Giles
BY: /s/ Naomi E. Sudranski
An Employee of WILSON ELSER MOSKOWITZ
EDELMAN & DICKER LLP

16
17
18
19
20
21
22
23
24
25
26
27
28
Page 3