Martin v. Target Corporation

Filing 22

ORDER Granting 21 Third Stipulation for Extension of Discovery Deadlines. Discovery due by 8/2/2018. Motions due by 9/4/2018. Proposed Joint Pretrial Order due by 10/4/2018. No further extensions will be granted. Signed by Magistrate Judge Nancy J. Koppe on 6/13/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02329-APG-NJK Document 21 Filed 06/12/18 Page 1 of 3

1
2
3
4

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

5
UNITED STATES DISTRICT COURT
6
DISTRICT OF NEVADA
7
REBECCA MARTIN, an Individual;

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

8
Plaintiff,
9
v.
10
11

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

STIPULATED REQUEST FOR
EXTENSION OF DISCOVERY
DEADLINES (Third Request)

12
Defendants.
13
14

The above named parties, by and through their respective counsel of record, hereby submit

15

the following STIPULATED REQUEST FOR EXTENSION OF DISCOVERY DEADLINES

16

(Third Request).

17

A.

18

This matter involves a slip and fall at one of defendant’s stores. On October 10, 2017, the

19

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

20
21
22
23

DISCOVERY COMPLETED TO DATE

documents on October 12, 2017. Plaintiff served her initial disclosure of witnesses and documents
on October 10, 2017.

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

Plan/Scheduling Order. On December 20, 2017, the Court entered an order granting the parties’ first
request to extend the discovery deadlines. On March 5, 2018, the Court entered an order granting
the parties’ second request to extend the discovery deadlines.

24
On October 17, 2017, defendant propounded a First Set of Interrogatories and First Set of
25
26
27
28

Requests for Production of Documents upon plaintiff.

Plaintiff served her responses to the

Interrogatories on November 20, 2017 and responses to the Requests for Production of Documents
on November 28, 2017.

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

Production of Documents upon defendant. On November 22, 2017, plaintiff propounded a Second
1328367v.1

Page 1 of 3

Case 2:17-cv-02329-APG-NJK Document 21 Filed 06/12/18 Page 2 of 3

1

Set of Requests for Production of Documents upon defendant. Defendant served its responses to the

2

First Set of Requests for Production of Documents on January 19, 2018 and served its responses to

3

the Second Set of Requests for Production of Documents on January 26, 2018.

4

Plaintiff conducted the deposition of one of defendant’s former employees on March 12,

5

2018. Plaintiff was unable to serve another one of defendant’s former employee with a subpoena

6

and vacated that deposition. Plaintiff conducted the deposition of a 30(b)(6) representative of

7

defendant regarding four issues on March 26, 2018. Plaintiff conducted the deposition of one of

8
9
10

defendant’s current employees on May 17, 2018. Plaintiff scheduled the deposition of a 30(b)(6)
representative of defendant regarding two additional issues for June 11, 2018. Plaintiff agreed to
reschedule that deposition as Defendant is in the process of substituting counsel.
The parties served initial expert witness disclosures on May 4, 2018. Defendant served a

11
12

supplemental expert witness disclosure on June 5, 2018.
B.

DISCOVERY THAT REMAINS TO BE COMPLETED

13
Defendant needs to conduct the deposition of plaintiff and up to four of plaintiff’s healthcare
14
15
16
17

providers. Plaintiff has scheduled the deposition of defendant’s 30(b)(6) representative regarding
two additional topics. Plaintiff may also conduct the depositions of additional employees and
representatives.

The parties also anticipate conducting the depositions of designated expert

witnesses.

18

C.

REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED

19

Defendant is in the process of substituting counsel in this matter. That substitution of

20

counsel has delayed the scheduling and completion of the remaining depositions as new counsel

21

becomes familiar with this matter and the parties schedule the depositions based upon new counsel’s

22

availability.

23

///

24
25

///

26
27

///

28
1328367v.1

Page 2 of 3

Case 2:17-cv-02329-APG-NJK Document 21 Filed 06/12/18 Page 3 of 3

1

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

2

D.

3

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

4
5
6
7
8
9

PROPOSED DISCOVERY SCHEDULE
August 2, 2018
September 4, 2018
October 4, 2018
Closed
Closed
Closed
Closed

DATED this 12th day of June, 2018.

DATED this 12th day of June, 2018.

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

THE GALLIHER LAW FIRM

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/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

10
11
12
13
14
15
16

NO FURTHER EXTENSIONS
WILL BE GRANTED.

IT IS SO ORDERED.
17
18

June 13
Dated this ______ day of ____________, 2018

19

______________________________________
UNITED STATES MAGISTRATE JUDGE

20
21
22
23
24
25
26
27
28
1328367v.1

Page 3 of 3