Taylor v. Target Corporation

Filing 15

ORDER granting 14 Motion to Extend Deadlines re Discovery. Discovery due by 4/27/2018. Motions due by 5/29/2018. Proposed Joint Pretrial Order due by 6/28/2018. If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order. Signed by Magistrate Judge Cam Ferenbach on 12/12/2017. (Copies have been distributed pursuant to the NEF - MMM)

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Kym S. Cushing
Nevada Bar No. 4242
Douglas M. Rowan
Nevada Bar No. 4736
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
[phone]; FAX [phone]
[e-mail]
[e-mail]
Attorneys for defendant Target Corporation

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Nita Taylor, individually;

Plaintiff,

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CASE NO.: 2:17-cv-02291-JCM-VCF

STIPULATION FOR EXTENSION OF
DISCOVERY DEADLINES (First Request)

vs.
Target Corporation; and DOES 1 through 100; and
ROE CORPORATIONS 101 through 200,

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Defendants.
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The above named parties, by and through their respective counsel of record, hereby submit
the following STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (First Request).

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A.

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This matter involves a slip and fall at one of Defendant’s stores. On September 29, 2017, the

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parties held an initial Rule 26(f) Conference. Defendant served its initial disclosure of witnesses and

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DISCOVERY COMPLETED TO DATE

documents on September 28, 2017.

Plaintiff served her initial disclosure of witnesses and

documents on September 29, 2017. On October 12, 2017, the Court entered a Stipulated Discovery
Plan/Scheduling Order.
On October 17, 2017, Defendant propounded a First Set of Interrogatories and First Set of
Requests for Production of Documents upon Plaintiff.

Plaintiff served her responses to the

Interrogatories on November 15, 2017 and responses to the Requests for Production of Documents
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on November 22, 2017. On October 12, 2017, Plaintiff propounded a First Set of Interrogatories and
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First Set of Requests for Production of Documents upon Defendant. Plaintiff has granted Defendant
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an extension to respond to those written discovery requests.
Defendant has requested Plaintiff’s medical records and films directly from her medical
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providers through records authorizations provided by Plaintiff.

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B.

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Defendant still needs to respond to Plaintiff’s written discovery requests. Defendant is still

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obtaining Plaintiff’s medical records through authorizations provided by Plaintiff. Defendant needs

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to conduct the deposition of Plaintiff and at least three of Plaintiff’s treating healthcare providers

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once Defendant has received Plaintiff’s medical records directly from the providers.

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continues to experience symptoms she attributes to the subject incident and anticipates requiring

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Plaintiff

future treatment so Defendant believes it is premature to conduct some of those depositions.
Defendant may seek to have Plaintiff appear for a Rule 35 Examination.
Plaintiff anticipates conducting the depositions of Defendant’s employees. The parties also

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DISCOVERY THAT REMAINS TO BE COMPLETED

anticipate designating expert witnesses and conducting the depositions of any designated expert
witnesses.
C.

REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED

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Defendant is still in the process of obtaining Plaintiff’s medical records and films. Defendant
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needs to obtain those records before conducting the depositions of Plaintiff and her treating
healthcare providers.

Defendant’s medical expert.

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Defendant also needs to obtain those records and films to provide to

The parties have discussed the possibility of early resolution of this matter, including the
potential scheduling of mediation. The parties would like to limit their expenses and conduct

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mediation prior to engaging in further discovery, including the disclosure of expert witnesses. The

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parties cannot schedule and conduct mediation, conduct additional discovery, and obtain reports

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from expert witnesses prior to the current deadline for the disclosure of expert witnesses.

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Accordingly, the parties request a sixty day extension of the current discovery deadlines.

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D.

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Close of Discovery:
Dispositive Motions:
Joint Pre-Trial Order:
Last day to amend pleadings:
Initial Expert Disclosures:
Rebuttal Expert Disclosures:
Interim Status Report

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PROPOSED DISCOVERY SCHEDULE
April 27, 2018
May 29, 2018
June 28, 2018
Closed
February 26, 2018
March 28, 2018
February 26, 2018

DATED this 8th day of December, 2017.

DATED this 8th day of December, 2017.

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

BERNSTEIN & POISSON

BY: _/s/ Douglas Rowan_______________
Kym S. Cushing
Nevada Bar No. 004242
Douglas M. Rowan
Nevada Bar No. 004736
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
Attorneys for defendant Target Corporation

BY:_/s/ Erik Bromson_____________
Scott L. Poisson
Nevada Bar No. 010188
Erik A. Bromson
Nevada Bar No. 009986
700 South Jones Boulevard
Las Vegas, Nevada 89107
Attorney for plaintiff Nita Taylor

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IT IS SO ORDERED.
December
12th
Dated this ______ day of ____________, 2017.

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______________________________________
UNITED STATES MAGISTRATE JUDGE

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If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended
until 30 days after decision on the dispositive motions or further court order.

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