STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST

GEORGE FOLEY, JR., Magistrate Judge.

In accordance with Local Rules of Practice for the United States District Court for the District of Nevada ("LR") 26-4, Defendant Albertson's LLC ("Defendant"), by and through its counsel of record, BACKUS, CARRANZA & BURDEN, and Plaintiff Danita Dailey-Adams ("Plaintiff"), by and through her counsel of record, BERTOLDO BAKER CARTER & SMITH, hereby stipulate and agree to an extension of all remaining discovery deadlines by ninety (90) days. The parties propose the following revised discovery plan:

DISCOVERY COMPLETED TO DATE

The parties conducted an Initial Disclosure Conference pursuant to LR 26-1 and Fed. R. Civ. P. 26(f) on November 28, 2017. In December 2017, the parties served their initial disclosure of documents and the names of individuals with knowledge of the facts pertaining to the claims set forth in this matter pursuant to Fed. R. Civ. P. 26(a)(1). On February 28, 2018, Defendant propounded interrogatories and requests for production of documents upon Plaintiff. On March 29, 2018, Plaintiff responded to Defendant's written discovery requests.

DISCOVERY TO BE COMPLETED

The parties will propound additional written discovery. Deposition of Plaintiff, representatives of Defendant, and other percipient witnesses remain to be taken. Defendant also anticipates deposing Plaintiff's medical providers. The parties are also expected to disclose and depose experts.

REASONS FOR EXTENSION TO COMPETE DISCOVERY

A discovery extension is needed in this case because Plaintiff has only recently completed her surgery which caused delay to her deposition and the depositions of her treating physicians. Thus, the parties respectfully request a ninety (90) day extension of the remaining discovery deadlines as detailed below. This request is made in good faith and not for the purpose of delay.

PROPOSED NEW DISCOVERY DEADLINES

ORDER

IT IS SO ORDERED.