Jarrell v. Walmart Inc et al

Filing 64

ORDER granting 63 Stipulation to Conitnue Motion in Limine Deadline. Motions in Limine are due 8/9/2021. Signed by Judge Andrew P. Gordon on 7/16/2021. (Copies have been distributed pursuant to the NEF - DRS)

1 DENNIS M. PRINCE
Nevada Bar No. 5092
2 ANGELA M. LEE
3 Nevada Bar No. 14905
PRINCE LAW GROUP
4 10801 W. Charleston Boulevard, Suite 560
Las Vegas, NV 89135
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Tel: [phone]
Fax: [phone]
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Email: [e-mail]
7 -And8 FARHAN R. NAQVI
Nevada Bar No. 8589
9 NAQVI INJURY LAW
9500 W. Flamingo Road, Suite 104
10 Las Vegas, NV 89147
11 Tel: [phone]
Fax: [phone]
12 Email: [e-mail]
Email: [e-mail]
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Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
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CLARK COUNTY, NEVADA
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LILIA JARRELL,

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Case No.: 2:18-cv-01219-APG-VCF

Plaintiff,
vs.
WAL-MART STORES, INC.; WALMART
INC. d/b/a WALMART #2593; INLAND
DIVERSIFIED LAS VEGAS EASTERN
BELTWAY, LLC; THE INLAND REAL
ESTATE GROUP, INC.; INLAND REAL
ESTATE INVESTMENT CORPORATION;
DOES 1 through 100 and ROE
CORPORATIONS 1 through 100, inclusive,

STIPULATION
AND ORDER TO CONTINUE
MOTION IN LIMINE DEADLINE
(FIRST REQUEST)

Defendant.
Plaintiff LILIA JARRELL (“Plaintiff”), by and through her attorneys of record,

28 Dennis M. Prince and Angela M. Lee of PRINCE LAW GROUP, and Farhan R. Naqvi
Page 1 of 3
10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135

1 and Paul G. Albright of the law firm NAQVI INJURY LAW, and Defendants WAL2 MART STORES, INC.; WALMART INC. d/b/a WALMART #2593 (hereinafter
3 collectively referred to as “Defendant Walmart”), by and through their attorneys of
4 record, Robert K. Phillips and Timothy D. Kuhls of the law firm PHILLIPS, SPALLAS
5 & ANGSTADT, LLC, submit this STIPULATION AND ORDER TO CONTINUE
6 MOTION IN LIMINE DEADLINE for the Court’s consideration.
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In the interest of judicial economy and efficiency, the parties request a brief

8 continuance of the Motion in Limine deadline. This is the first request to extend the
9 Motion in Limine deadline, though the Motion in Limine deadline has been previously
10 altered three times. The first extension was a result of the parties’ stipulation to extend
11 discovery on October 17, 2018 (ECF 16, 17). The second extension was a result of the
12 parties’ stipulation to continue trial on October 14, 2020 (ECF 43, 44). The third
13 extension was a result of the parties’ stipulation to continue trial on February 10, 2021
14 (ECF 52, 53).
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The parties have been diligent in this matter, but various upcoming events may

16 affect the subject Motions in Limine. On July 14, 2021, the parties met and conferred
17 regarding our respective Motions in Limine pursuant to LR 16-3(a). Although the parties
18 were able to agree on many evidentiary issues, the parties collectively have more than
19 30 Motions in Limine that they intend to file. Some of these motions, however, are
20 dependent upon the Court’s ruling regarding Plaintiff’s Emergency Motion to Substitute
21 Plaintiff’s Expert Witness Dr. Gross with Dr. Oliveri (ECF 56). The outcome of Plaintiff’s
22 Motion to Substitute may also affect the Motion in Limine due date. Moreover, there is
23 an upcoming Master Trial Calendar Scheduling Conference on August 3, 2021, which
24 may further affect the Motion in Limine due date.
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A continuance of the Motion in Limine due date will provide additional time

26 during which the Court may render a ruling on Plaintiff’s Motion to Substitute which
27 will provide clarity on various Motions in Limine that the parties intend to file.
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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135

1 Moreover, the continuance will allow the parties to attend the Master Trial Calendar
2 Scheduling Conference to determine when the trial will be and when the Motions in
3 Limine will be due in accordance with the trial date. Accordingly, the parties are
4 requesting a brief two-week extension to file our Motions in Limine from July 23, 2021,
5 to Monday, August 9, 2021.
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DATED this 15th day of July, 2021

DATED this 15th day of July, 2021

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PRINCE LAW GROUP

PHILLIPS, SPALLAS & ANGSTADT

/s/ Dennis M. Prince
________________________________
DENNIS M. PRINCE
Nevada Bar No. 5092
ANGELA M. LEE
Nevada Bar No. 14905
10801 W. Charleston Blvd., Suite 560
Las Vegas, NV 89135
-AndFARHAN R. NAQVI
Nevada Bar No. 8589
PAUL G. ALBRIGHT
Nevada Bar No. 14159
NAQVI INJURY LAW
Nevada Bar No. 14159
9500 W Flamingo Road, Suite 104
Las Vegas, Nevada 89147
Attorneys for Plaintiff

/s/ Timothy Kuhls
_______________________________
ROBERT K. PHILLIPS
Nevada Bar No. 11441
TIMOTHY D. KUHLS
Nevada Bar No. 13362
504 South Ninth Street
Las Vegas, Nevada 89101
Attorneys for Defendants

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IT IS SO ORDERED:

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__________________________________
UNITED STATES DISTRICT JUDGE

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July 16, 2021
DATED: _________________

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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135