Williams v. 99 Cents Only Stores LLC

Filing 16

ORDER Granting in part and Denying in part 15 Stipulation for extension of discovery deadlines. It is granted in all respects except that the discovery cut off shall be January 13, 2023. Motions due by 2/13/2023. Signed by Magistrate Judge Brenda Weksler on 9/19/2022. (Copies have been distributed pursuant to the NEF - LOE)

Case 2:22-cv-00139-APG-BNW Document 16
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Scott L. Poisson, Esq.
Nevada Bar No.: 10188
Amber N. King, Esq.
Nevada Bar No.: 14070
BERNSTEIN & POISSON
700 South Jones
Las Vegas, Nevada 89107
[phone]
[phone] fax
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Plaintiff,

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v.

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Case No.: 2:22-cv-139-APG-BNW

ELVIA WILLIAS, an individual,

99 CENTS ONLY STORES, LLC., and; DOES 1

STIPULATION AND PROPOSED
ORDER FOR EXTENSION OF
DISCOVERY DEADLINES
[SECOND REQUEST]

through 100; and ROE CORPORATION 101
through 200, inclusive,

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Defendant(s).
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Plaintiff, Elvia Williams, by and through her counsel of record, the law firm of
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Bernstein & Poisson and Defendant, 99 Cents Only Stores, by and through its attorneys
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of record, hereby stipulate and request to extend the respective Discovery Deadlines in this
case as follows:
I.

DISCOVERY COMPELTED TO DATE

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All parties have served disclosures of documents and witnesses. All parties have

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served and responded to interrogatories, requests for production of documents, and

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request for admissions. The deposition of Plaintiff has been completed.

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DISCOVERY REMAINING

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1. Deposition of Defendant or 30(b)(6)

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2. Independent Medical Examine of Plaintiff

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3. Expert Disclosures

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II.

THE REASONS WHY THE DISCOVERY REMANINING CANNOT BE

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COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY

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ORDER

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The parties have diligently been obtaining the necessary discovery in this matter,
however, due to the COVID-19 restrictions and delays, some discovery, including
depositions of non-party witnesses have not been able to be completed. Accordingly, the

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parties request a 60-day extension of the discovery deadlines.
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III.

CURRENT DEADLINES

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1. November 15, 2022 – close of discovery.
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2. Closed – final date to amend pleadings and add parties.

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3. September 16, 2022 – final date to make expert disclosures.

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4. October 17, 2022 – final date to make rebuttal expert disclosures.

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5. December 15, 2022 – final date to file dispositive motions.

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IV.

Proposed Schedule For Completing All Remaining Discovery

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1. January 13, 2022 – close of discovery.

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2. Closed – final date to amend pleadings and add parties.

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3. November 15, 2022 – final date to make expert disclosures.

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4. December 16, 2022 – final date to make rebuttal expert disclosures.

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5. February 13, 2023 – final date to file dispositive motions.

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BERNSTEIN & POISSON

PERRY, SPANN, & WESTBROOK, P.C

DATED: SEPTEMBER 14, 2022

DATED: SEPTEMBER 14, 2022

/s/ Amber N. King
Scott L. Poisson, Esq.
Nevada Bar No.: 10188
Amber N. King, Esq.
Nevada Bar No.: 14070
700 South Jones Blvd.,
Las Vegas, Nevada 89107
Attorneys for Plaintiff

/s/ Lew Brandon, Jr.
Lew Brandon, Jr., Esq.
Nevada Bar No. 5880
Andrew Guzik, Esq.
Nevada Bar No. 12758
139 E. Warm Springs Road
Las Vegas, NV 89119
Attorneys for Defendant

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IT IS SO ORDERED:
ORDER

IT IS ORDERED that ECF No. 15 is GRANTED in part and
DENIED in part. It is granted in all respects except that the
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discovery cut off shall be January
13, 2023.

UNITED STATES MAGISTRATE JUDGE

IT IS SO ORDERED

DATED: 1:36 pm, September 19, 2022

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DATED: ______________________

BRENDA WEKSLER
UNITED STATES MAGISTRATE JUDGE

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Case 2:22-cv-00139-APG-BNW Document 16
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Sabina Damelas
From:
Sent:
To:
Cc:
Subject:

Andrew Guzik <[e-mail]>
Wednesday, September 14, 2022 11:47 AM
Sabina Damelas; Amber King
April Rufus; Maybelline Valle; Homero Gonzalez
RE: Elvia Williams v. 99 Cents Only Stores

You can add my electronic signature to the stipulation. Thanks
ANDREW GUZIK, ESQ.
BRANDON | SMERBER LAW FIRM
139 E. WARM SPRINGS RD.
LAS VEGAS, NEVADA 89119
TEL. [phone]
FAX. [phone]

From: Maybelline Valle <[e-mail]>
Sent: Wednesday, September 14, 2022 9:52 AM
To: Andrew Guzik <[e-mail]>; Homero Gonzalez <[e-mail]>
Cc: April Rufus <[e-mail]>
Subject: FW: Elvia Williams v. 99 Cents Only Stores
Please see attached proposed SAO to Extend Discovery.
Best Regards,

Maybelline Valle, Legal Assistant to
Lew Brandon, Jr. Esq.
Andrew Guzik, Esq.
Homero Gonzalez, Esq.
David Spurlock Jr., Esq.
BRANDON | SMERBER LAW FIRM
139 E. Warm Springs Rd.
Las Vegas, NV 89119
Tel: [phone]
Fax: [phone]
The information contained in the electronic message is legally privileged and confidential under applicable law, and is
intended only for the use of the individual or entity named above. If the recipient of this message is not the above-named
intended recipient, you are hereby notified that any dissemination, copy or disclosure of this communication is strictly
prohibited. If you have received this communication in error, please notify Brandon│Smerber Law Firm at [phone]
and permanently delete the communication immediately without making any copy or distribution.
From: Sabina Damelas <[e-mail]>
Sent: Wednesday, September 14, 2022 9:38 AM
To: Maybelline Valle <[e-mail]>
Cc: Amber King <[e-mail]>
Subject: FW: Elvia Williams v. 99 Cents Only Stores
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