Taylor v. Target Corporation

Filing 17

ORDER Granting 16 Stipulation re Discovery Deadlines. Discovery due by 6/26/2018. Motions due by 7/26/2018. Proposed Joint Pretrial Order due by 8/27/2018. Signed by Magistrate Judge Cam Ferenbach on 2/13/2018. (Copies have been distributed pursuant to the NEF - MMM)

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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]
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;

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

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

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STIPULATION FOR EXTENSION OF
DISCOVERY DEADLINES (Second
Request)

Defendants.

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

DISCOVERY COMPLETED TO DATE

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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documents on September 28, 2017.

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documents on September 29, 2017. On October 12, 2017, the Court entered a Stipulated Discovery

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Plan/Scheduling Order. On December 12, 2017, the Court entered an order granting the parties first

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request to extend the discovery deadlines.

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Plaintiff served her initial disclosure of witnesses and

On October 17, 2017, Defendant propounded a First Set of Interrogatories and First Set of

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Requests for Production of Documents upon Plaintiff.

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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. Defendant served its responses

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to those written discovery requests on January 4, 2018.
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Plaintiff served her responses to the

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Defendant has requested Plaintiff’s medical records and films directly from her medical
providers through records authorizations provided by Plaintiff.

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B.

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Defendant is still obtaining Plaintiff’s medical records through authorizations provided by

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Plaintiff. Defendant needs to conduct the deposition of Plaintiff and at least three of Plaintiff’s

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treating healthcare providers once Defendant has received Plaintiff’s medical records directly from

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the providers. Plaintiff continues to experience symptoms she attributes to the subject incident and

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anticipates requiring future treatment so 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 agreed to conduct a mediation in this matter before engaging in extensive
discovery, including the disclosure of expert witnesses. The first mutually agreeable date on which

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the parties could schedule mediation is April 10, 2018, which is after the current deadline to disclose

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

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deadlines.

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...

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...

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...

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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
June 26, 2018
July 26, 2018
August 27, 2018
Closed
April 27, 2018
May 29, 2018
April 27, 2018

DATED this 12th day of February, 2018.

DATED this 12th day of February, 2018.

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

BERNSTEIN & POISSON

BY: /s/Douglas M. Rowan
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 A. 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.

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February
13th
Dated this ______ day of ____________, 2018

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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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