Francisca Melendez v. United States of America; Does I – X and Roe Corporations I – X, inclusive

Opinion

TAOctDinDg ABtLtoArnNeCy HGEe neral of the United States First Assistant United States Attorney District of Nevada Nevada Bar Number 8264 Assistant United States Attorney Nevada Bar No. 5144 501 Las Vegas Blvd. So., Suite 1100 Las Vegas, Nevada 89101 Telephone: (702) 388-6336 Facsimile: (702) 388-6787 James.Sweetin@usdoj.gov Attorneys for the United States of America DISTRICT OF NEVADA FRANCISCA MELENDEZ, individually, Case No. 2:25-cv-00724-RFB-EJY Plaintiff, Stipulation and Order to Extend v. Discovery Deadlines or in the Alternative Stay the Remaining UNITED STATES OF AMERICA; DOES I Discovery Deadlines. – X and ROE CORPORATIONS I – X, inclusive, (Third Request) Defendants. This matter is set for an in-person settlement conference on Tuesday, September 29, 2026. In light of the settlement conference and pursuant to LR IA 6-1 and LR 26-3, the parties request a ninety (90) day extension of the discovery deadlines. The parties have conducted discovery diligently and in good faith. This is the third request for an extension of the discovery deadlines. This action arises under the Federal Tort Claims Act (“FTCA”)1 for alleged injuries to Plaintiff arising from a January 20, 2023, fall at an USPS office. The deadline to amend parties and/or add parties has passed. The remaining deadlines are July 29, 2026, for initial expert disclosures, August 31, 2026, for rebuttal expert disclosures, September 28, 2026, for 1 28 U.S.C. §§ 1346(b)(1), 1402(b), 2401(b), 2402, 2671-2680. discovery cutoff, October 27, 2026, for dispositive motions and November 25, 2026, for the proposed joint pretrial order. The parties’ counsel conferred and agreed that ninety (90) days extension would be proper and would conserve their resources, as well as those of the Court, if the remaining discovery deadlines including disclosure of initial experts, rebuttal experts, additional discovery, dispositive motions, if any, and preparation of the proposed joint pretrial order, are moved until after the settlement conference for this matter set on September 29, 2026. Accordingly, the parties respectfully ask the Court to extend the discovery deadlines as follows: Scheduled Event Current Deadline Proposed Deadline Initial Expert Disclosures July 29, 2026 October 27, 2026 Rebuttal Expert Reports August 31, 2026 November 30, 2026 Discovery Cut Off September 28, 2026 December 28, 2026 Dispositive Motions October 27, 2026 January 25, 2027 Pre-Trial Order November 25, 2026 February 23, 20272 If dispositive motions are filed, the joint pre-trial order would be due 30 days after a decision on such motions. Disclosures under Fed. R. Civ. P. 26(a)(3), and any objections thereto, shall be included in the Joint Pretrial Order. If this Court is not inclined to extend the remaining discovery deadlines, in the alternative the parties are respectfully requesting that the Court stay the remaining discovery deadlines. A district court has wide latitude in controlling discovery, Volk v. D.A. Davidson & Co., 816 F.2d 1406, 1416–17 (9th Cir. 1987), as well as the inherent power to stay causes on its docket to avoid duplicative litigation, inconsistent results, and waste of time and 2 If dispositive motions were filed, the deadline for the Proposed Joint Pretrial Order would effort, Stern v. United States, 563 F. Supp. 484, 489 (D. Nev. 1983) (Supreme Court citations omitted). If this case were not resolved at the settlement conference, the parties agree to submit within 14 days thereafter a new, proposed schedule for expert disclosures, dispositive motions and the proposed joint pretrial order. Respectfully submitted this 13th day of July 2026. ER INJURY ATTORNEYS TODD BLANCHE Acting Attorney General of the United States SIGAL CHATTAH First Assistant United States Attorney /s/Justin G. Randall /s/ James R. Sweetin Nevada Bar No. 12476 Assistant United States Attorney 1700 S. Pavilion Center Dr., Ste. #530 Attorneys for Federal Defendants Las Vegas, NV 89135 Attorney for Plaintiff IT HEREBY ORDERED that the Stipulation to extend discovery (ECF No. [22] is UNITED STATES MAGISTRATE JUDGE DATED: July 13, 2026