Renteria v. Albertson's LLC

• Court: District Court, D. Nevada
• Decided: May 8, 2023
• Docket: 2:22-cv-02048
• Status: Unknown

Opinion

1 JNaecvka Pd.a BSutartdee nB,a Er sNqo. . 6918 2 Jacquelyn Franco, Esq. Nevada State Bar No. 13484 3 Dallin Knecht, Esq. 4 Nevada State Bar N. 16263 BACKUS | BURDEN 5 3050 South Durango Drive Las Vegas, NV 89117 6 (702) 872-5555 (702) 872-5545 7 jburden@backuslaw.com 8 JaquelynFranco@backsulaw.com dallinknecht@backuslaw.com 9 Attorneys for Defendants, Albertson’s LLC and Albertson’s Stores Sub, LLC 10 UNITED STATES DISTRICT COURT 11

12 DISTRICT OF NEVADA

13 MARIA DE JESUS BRIONES RENTERIA, as ) Case No. 2:22-cv-02048-RFB-BNW an individual ) 14 ) STIPULATION AND [PROPOSED] Plaintiff, ) ORDER TO EXTEND DISCOVERY 15 vs. ) DEADLINES 16 ) (First Request) ALBERTSON’S LLC; ALBERTSON’S ) 17 STORES SUB, LLC; DOE MANAGER; DOE ) JANITOR; DOE EMPLOYEERS; DOES I-X; ) 18 and ROE CORPORATIONS I-X, inclusive, ) ) 19 Defendants. ) 20 Plaintiff Maria De Jesus Briones Renteria, and Defendants Albertson’s LLC and 21 Albertson’s Stores Sub, LLC, do hereby stipulate and agree to the extension of the discovery 22 deadlines in the current scheduling order and discovery plan in this matter for a period of sixty 23 24 (60) days for the reasons explained herein. 25 Pursuant to Local Rule IA 6-1(a), the parties state that this if the first such discovery 26 extension requested in this matter. 27 . . . 28 1 DISCOVERY COMPLETED TO DATE – LR 26-3(a) 2 1. Plaintiff served Initial FRCP 26 Disclosures on January 1, 2023 3 4 2. Plaintiff served written discovery on January 10, 2023 5 3. Defendant served Initial FRCP 26 Disclosures on January 12, 2023 6 4. Defendant served written discovery on February 6, 2023 7 5. Defendant served its First Supplemental FRCP 26 Disclosure on February 9, 2023 8 6. Defendant responded to Plaintiff’s written discovery on February 9, 2023 9 7. Defendant served its Second Supplemental FRCP Disclosure on March 2, 2023 10 8. Plaintiff responded to Defendant’s written discovery on March 23, 2023 11 12 DISCOVERY REMAINING – LR 26-3)b)

13 1. Deposition of Plaintiff (Noticed for May 23, 2023 14 2. Deposition of Defendant employees (Noticed for May 11, 2023 15 3. Deposition of Defendant’s 30(b)(6) designee 16 4. Disclosure of expert witnesses 17 5. Disclosure of rebuttal witnesses 18 6. Depositions of Plaintiff’s treating physicians 19 20 7. Depositions of Experts 21 8. Additional depositions (as needed) 22 REASONS FOR EXTENSION – LR 26-3(c)

23 Pursuant to LR IA 6-1 and LR 26-3, the parties represent that good cause exists for the 24 extension of the current discovery deadlines. The parties have experienced delay in the scheduling 25 of depositions and based on information learned through discovery anticipate taking more 26 depositions than initially contemplated. 27 28 The parties have acted in good faith in discovery to date. Neither party has any intent, nor 1 consult, and retain the proper experts to support their case, as well as allow necessary time for all 2 depositions. 3 NEW DISCOVERY DEADLINES – LR 26-3(d) 4 Current Deadline New Deadline 5 Deadline For Expert Witnesses May 29, 2023 July 28, 2023 6 Deadline To Amend Pleadings/Add Parties Closed Closed 7 8 Deadline For Rebuttal Experts June 28, 2023 August 26, 2023 9 Discovery Deadline July 28, 2023 September 26, 2023 10 Deadline To File Dispositive Motions August 28, 2023 October 27, 2023 11 Pretrial Order Deadline September 27, 2023 November 27, 2023 12

13 . . . 14 . . . 15 . . . 16 . . . 17 . . . 18 19 . . . 20 . . . 21 . . . 22 . . . 23 . . . 24 . . . 25 . . . 26 27 . . . 28 1 If this extension is granted, all anticipated additional discovery should be concluded 2 within the stipulated extended deadline. The parties represent that this request for extension of 3 discovery deadlines is made by the parties in good faith and not for the purpose of delay. 4 5 6 | IT ISSO STIPULATED and agreed as to the terms and conditions of this Stipulation to Extend 7 || Discovery Deadlines. 8 9 DATED: May 5, 2023 DATED: May 5, 2023 10 || /s/ Peter A. Mazzeo /s/Jack P. Burden Peter A. Mazzeo, Esq. Jack P. Burden, Esq. 11 || Mazzeo Law LLC Dallin Knecht, Esq. 631 South 10" Street Backus | Burden Las Vegas, Nevada 89101 3050 S. Durango Dr. 13 Attorney for Plaintiff Las Vegas, Nevada 89117 Attorneys for Defendants 14 15 ORDER 16 IT ISSO ORDERED 17 DATED: 3:55 pm, May 08, 2023 18 19 Les Arba, BRENDA WEKSLER 20 UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28