Kelly v. Walmart Inc.

Filing 18

ORDER granting 17 Stipulation to Extend Discovery deadlines. Discovery due by 4/30/2021. Motions due by 5/28/2021. Proposed Joint Pretrial Order due by 6/25/2021. Signed by Magistrate Judge Elayna J. Youchah on 1/8/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-01129-GMN-EJY Document 18 Filed 01/08/21 Page 1 of 3

1
2
3
4
5
6
7

Gina M. Corena, Esq.
Nevada Bar No. 10330
[e-mail]
Mahna Pourshaban, Esq.
Nevada Bar No. 13743
[e-mail]
GINA CORENA & ASSOCIATES
300 S. Fourth Street, Suite 1250
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Kathryn Kelly

8
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11

KATHRYN KELLY, an individual,

12

CASE NO. 2:20-cv-01129-GMN-EJY

Plaintiff,
STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES

13

v.

14

WALMART, INC.; DOES I - X, and ROE [THIRD REQUEST]
Corporations I - X, inclusive,

15
16

Defendants.

17
18
19

Plaintiff KATHRYN KELLY (hereinafter “Plaintiff”) and Defendant WALMART INC.
(hereinafter “Defendant” or “Walmart”), by and through their respective counsel of record, do

20

hereby stipulate to extend the discovery deadlines in the current scheduling order and discovery

21

plan in this matter for a period of forty-five (45) days for the reasons explained herein.

22
23
24
25
26

Pursuant to Local Rule 6-1(b), the parties hereby aver that this is the third such discovery
extension requested in this matter.
The parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested
extension. The parties agree, pending the Court’s approval, to extend discovery deadlines, and
stipulate that the request is appropriate. Counsel for Plaintiff, Mahna Pourshaban, Esq., has

27
fallen ill with Covid, causing a temporary impairment in her ability to sufficiently proceed in the
28

Case 2:20-cv-01129-GMN-EJY Document 18 Filed 01/08/21 Page 2 of 3

1

prosecution of this matter, as it relates to retention and disclosure of expert witnesses.

2
3

The parties have acted in good faith to request this extension and have no intent, nor
reason, to delay the resolution of this matter.

4

NEW DISCOVERY DEADLINES

5

Expert Disclosure Deadline:

6
Currently:

January 15, 2021

Proposed:

March 1, 2021

7
8

Rebuttal Expert Disclosure Deadline:

9
10

Currently:

February 15, 2021

11

Proposed:

April 1, 2021

12

Discovery Cut-Off Date:

13

Currently:

March 16, 2021

Proposed:

April 2, 2021 April 30, 2021

14
15

Dispositive Motion Deadline:

16
Currently:

April 15, 2021

Proposed:

May 28, 2021

17
18

Proposed Joint Pre-Trial Deadline:

19
20

Currently:

May 13, 2021

21

Proposed:

June 25, 2021

22
23
24
25
26
27
28

All other deadlines dates remain the same.
///
///
///

Case 2:20-cv-01129-GMN-EJY Document 18 Filed 01/08/21 Page 3 of 3

1

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

2

within the stipulated deadline. This request for extension deadline is made by the parties in good

3

faith and not for the purpose of delay.

4
5

DATED this 6th day of January, 2021.

DATED this 8th day of January, 2021.

GINA CORENA & ASSOCIATES

PHILLIPS, SPALLAS & ANGSTADT, LLC

/s/ Mahna Pourshaban
_____________________________
Mahna Pourshaban, Esq.
Nevada Bar No. 13743
300 South Fourth St., Suite 1250
Las Vegas, NV 89101
Attorney for Plaintiff

/s/ Latisha Robinson
______________________________
Latisha Robinson, Esq.
Nevada Bar No. 15314
504 S. Ninth St.
Las Vegas, NV 89101
Attorney for Defendant

6
7
8
9
10
11
12
13
14

IT IS SO ORDERED; provided, however, that
the close of discovery shall be April 30,
2021, rather than the April 2, 2021 date
stated above.

15
16
17
18
19
20
21
22
23
24
25
26
27
28

______________________________________
UNITED STATES MAGISTRATE JUDGE
Dated: January 8, 2021