Martin v. Target Corporation

Filing 15

ORDER Granting 14 Stipulation for Extension of Discovery Deadlines (First Request). Discovery due by 5/4/2018. Motions due by 6/4/2018. Proposed Joint Pretrial Order due by 7/5/2018. Signed by Magistrate Judge Nancy J. Koppe on 12/20/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02329-APG-NJK Document 14 Filed 12/19/17 Page 1 of 3

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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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REBECCA MARTIN, an Individual;

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CASE NO.: 2:17-cv-02329-APG-NJK

Plaintiff,
STIPULATION FOR EXTENSION OF
DISCOVERY DEADLINES (First Request)

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v.

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TARGET CORPORATION, a Foreign Corporation;
YET UNKNOWN EMPLOYEE; DOES I through
X, inclusive,

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

DISCOVERY COMPLETED TO DATE

This matter involves a slip and fall at one of defendant’s stores. On October 10, 2017, the
parties held an initial Rule 26(f) Conference. Defendant served its initial disclosure of witnesses and
documents on October 12, 2017. Plaintiff served her initial disclosure of witnesses and documents

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on October 10, 2017.

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Plan/Scheduling Order.

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On October 17, 2017, the Court entered a Stipulated Discovery

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 20, 2017 and responses to the Requests for Production of Documents

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on November 28, 2017.

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Production of Documents upon defendant. Plaintiff has granted defendant an extension to respond

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to those written discovery requests. On November 22, 2017, plaintiff propounded a Second Set of
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Plaintiff served her responses to the

On October 30, 2017, plaintiff propounded a First Set of Requests for

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Requests for Production of Documents upon defendant.
On November 22, 2017, plaintiff noticed the deposition of one of defendant’s current

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employees and the deposition of one of defendant’s former employees for February 6, 2018.
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 is still obtaining plaintiff’s medical records through authorizations provided by

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DISCOVERY THAT REMAINS TO BE COMPLETED

plaintiff. Defendant needs to conduct the deposition of plaintiff and possibly four of plaintiff’s
treating healthcare providers once defendant has received plaintiff’s medical records directly from
the providers. Additionally, plaintiff suffered a prior injury at work, and defendant may seek to
depose any healthcare providers who provided treatment for that injury once defendant obtains the
medical records regarding that treatment. Plaintiff continues to experience symptoms she attributes
to the subject incident so defendant may seek to have plaintiff appear for a Rule 35 Examination.

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Defendant needs to respond to plaintiff’s written discovery requests.
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Plaintiff has scheduled the deposition of one of defendant’s former and one of defendant’s
current employees and may conduct the depositions of additional employees and representatives.
The parties also anticipate designating expert witnesses and conducting the depositions of any
designated expert witnesses.

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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 prior and current

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treating healthcare providers. Defendant also needs to obtain those records and films to provide to

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defendant’s medical expert. Also, plaintiff continues to experience symptoms she attributes to the

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subject incident, and defendant may seek to have her appear for a Rule 35 Examination. All of this

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discovery cannot be completed and provided to expert witnesses to allow them to complete expert

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reports prior to the current initial expert disclosure deadline. Accordingly, the parties request a sixty

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day extension of the current discovery deadlines.

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...

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...
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Case 2:17-cv-02329-APG-NJK Document 14 Filed 12/19/17 Page 3 of 3

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D.

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PROPOSED DISCOVERY SCHEDULE
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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May 4, 2018
June 4, 2018
July 5, 2018
Closed
March 5, 2018
April 4, 2018
March 5, 2018

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DATED this __ day of December, 2017.

DATED this __ day of December, 2017.

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WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

THE GALLIHER LAW FIRM

BY: _/s/ Kym S. Cushing____________
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/ Keith E. Galliher___________
Keith E. Galliher, Jr.
Nevada Bar No. 000220
1850 East Sahara Avenue, Suite 107
Las Vegas, Nevada 89104
Attorney for plaintiff Rebecca Martin

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IT IS SO ORDERED.
December 20
Dated this ______ day of ____________, 2017.

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______________________________________
UNITED STATES MAGISTRATE JUDGE

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