Alcaraz v. Conagra Brands, Inc. ( 2021 )

1 || PETER S. CHRISTIANSEN, ESQ. Nevada Bar No. 005254 2 || pete@christiansenlaw.com R. TODD TERRY, ESQ. 3 || Nevada Bar No. 6519 tterry@christiansenlaw.com 4 || WHITNEY J. BARRETT, ESQ. Nevada Bar No. 13662 5 || wbarrett@christiansenlaw.com CHRISTIANSEN TRIAL LAWYERS 6 || 710 S. 7 Street Las Vegas, Nevada 89101 7 || Telephone: (702) 240-7979 2 Facsimile: (866) 412-6992 9 Attorneys for Plaintiff | 10 UNITED STATES DISTRICT COURT ll DISTRICT OF NEVADA 12 || KYLE A. ALCARAZ, an individual; CASE NO. 2:20-cev-01414-JCM-EJY 1B Plaintiff, < 14 || v. 15 CONAGRA BRANDS, INC.; CONAGRA STIPULATION AND ORDER TO ~ FOODS, INC.; SAM’S WEST, INC. dba EXTEND DISCOVERY AND 16 SAM’S CLUB; DOES | through 10; and OTHER DEADLINES | ROE BUSINESS ENTITIES 1 through 10, (SECOND REQUEST) 17 inclusive; 18 Defendants. 19 Plaintiff, KYLE A. ALCARAZ, by and through his attorneys of record, PETER § 20 || CHRISTIANSEN, ESQ., R. TODD TERRY, ESQ., and WHITNEY J. BARRETT, ESQ. o 21 || CHRISTIANSEN TRIAL LAWYERS, and Defendants CONAGRA BRANDS, INC 22 || CONAGRA FOODS, INC., and SAM’S WEST, INC., by and through their attorneys, J 23 || CHRISTOPHER JORGENSEN, ESQ. of LEWIS ROCA ROTHGERBER CHRISTIE LLF 24 || hereby file their second joint application to extend the discovery cut off period and other deadline 25 || in this case, pursuant to LR II 26-4. The present discovery cutoff date is August 2, 2021. 26 I. DISCOVERY COMPLETED 27 1. Plaintiff produced his initial FRCP 26(a)(1) disclosure and two supplement 28 1 thereto; 2 2. Defendants produced their initial FRCP 26(a)(1) disclosure; and 3 3. The parties have propounded and responded to written discovery requests. 4 Il. DISCOVERY TO BE COMPLETED 5 1. Plaintiff will take the depositions of Defendants’ corporate designees an 6 employees; 2. Defendants will depose Plaintiff; 3. The parties will disclose expert witnesses and depose their respective experts; ° 4. The parties intend to serve, and respond to, additional written discovery; and | 5. The parties intend to subpoena and conduct the depositions of third parties, fac □ witnesses, Plaintiff's treating providers, and the parties’ experts. B Wl. GOOD CAUSE WHY THE DISCOVERY REMAINING WAS NO’