STIPULATION AND ORDER FOR EXTENSION OF TIME TO COMPLETE DISCOVERY (SECOND REQUEST

C.W. HOFFMAN, JR., Magistrate Judge.

Plaintiff, SANDRA DE BLANC, and Defendant, ALOHA AIRPORT EXPRESS, by and through their respective counsel, and pursuant to Local Rule 26-4, stipulate to modify their discovery plan as follows:

1. Plaintiff filed her Complaint in the Eighth Judicial District Court for Clark County, Nevada on October 20, 2017. Defendant removed the action to this Court on January 26, 2018 (ECF No. 1).

2. The parties held their F.R.C.P. 26 conference on March 5, 2018 and filed their initial Stipulated Discovery Plan and Scheduling Order in compliance with F.R.C.P. 26(f) and LR 26-1(e) on March 7, 2018 (ECF No. 16). The parties filed a Stipulation and Order for Extension of Time to Complete Discovery (First Request) on April 27, 2018. In the first Stipulation for the extension of the discovery deadlines, the parties agreed to the following dates:

The Stipulation and Order for Extension of Time to Complete Discovery (First Request) was signed by United States Magistrate Judge Carl W. Hoffman on May 1, 2018 (ECF No. 21).

3. In compliance with Local Rule 26-4, the parties provide the following information regarding the discovery status:

a. Discovery Completed: The parties have exchanged initial disclosures of witnesses and documents, have served written discovery, Plaintiff's deposition has been taken and the parties have exchanged initial expert disclosures.

b. Discovery that remains to be completed: Additional time is needed for Defendant to schedule and conduct the depositions of Plaintiff's expert witnesses William Muir, M.D. and Lane Swainston and Plaintiff to schedule and conduct the depositions of Defendant's driver Daniel Leivas and Defendant's FRCP 30(b)(6) witness Michael Logan, both of whose depositions must be taken out-of-state in Arizona. No further discovery is anticipated at this time; however, additional discovery may be required based upon the deposition testimony of those witnesses. The parties have been diligently working with each other and co-operating with discovery requests as necessary. Based on the foregoing, the parties are requesting additional time to complete the discovery set forth above.

c. Reasons why discovery was not completed: There is good cause for a sixty (60) day extension of the discovery cutoff deadline. Counsel have been working diligently to attempt to adhere to the current discovery time lines. However, due to the congested schedules of counsel, including trial obligations, the parties require additional time to conclude the limited discovery set forth above. Thus, the request for additional time is being requested. The instant request is not made for purposes of delay. The parties are working diligently to complete all remaining discovery.

d. Proposed schedule for completion of remaining discovery (extension of remaining deadlines by sixty 60 days):

IT IS SO ORDERED: