Lewis v. Walgreen Co.

Filing 12

ORDER granting 11 Stipulation; Discovery due by 2/11/2019. Motions due by 3/12/2019. Proposed Joint Pretrial Order due by 4/11/2019. Signed by Magistrate Judge Peggy A. Leen on 8/21/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:18-cv-00827-JAD-PAL Document 11 Filed 08/17/18 Page 1 of 4

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JAMES F. HOLTZ, ESQ.
Nevada Bar No. 8119
MICHAEL G. TRIPPIEDI, ESQ.
Nevada Bar No. 13973
RANALLI ZANIEL FOWLER & MORAN, LLC
2400 W. Horizon Ridge Parkway
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for WALGREEN CO.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

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Darvis Lewis, individually,

Case No.: 2:18-cv-00827-JAD-PAL

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Plaintiff.
STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES AND TRIAL
(First Request)

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vs.
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WALGREEN CO., d/b/a Walgreen’s;
and DOES 1 through 100; and ROE
CORPORATIONS 101 through 200,

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Defendant.
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES AND TRIAL
(First Request)

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Pursuant to Local Rules 6-1 and 26-4, the parties, by and
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through their respective counsel of record, hereby stipulate to
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and request that the Court extend the deadlines by ninety days.
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DISCOVERY COMPLETED
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The following discovery has been completed by the parties:
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1.

Proposed

Joint

Discovery

Plan

and

Scheduling

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dated July 13, 2018.
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)

Order

Case 2:18-cv-00827-JAD-PAL Document 11 Filed 08/17/18 Page 2 of 4

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2.

Defendant’s Initial FRCP 26(f) Disclosure dated June

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26, 2018;

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3.

Plaintiff’s First Set of Interrogatories to Defendant

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dated July 23, 2018.

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4.

Plaintiff’s First Request for Production of Documents

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to Plaintiff dated July 24, 2018;

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5.

Defendant’s First Request for Production of Documents

HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

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to Plaintiff dated August 15, 2018;

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6.

Defendant’s First Set of Interrogatories to Plaintiff

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dated August 15, 2018.
DISCOVERY TO BE COMPLETED

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1.

Obtain Plaintiff’s medical records;

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2.

The parties may retain expert witnesses;

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3.

Depositions of parties;

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4.

Depositions

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of

expert

witness(es)

and

Plaintiff’s

treating physician(s).
REASONS THAT DISCOVERY HAS NOT YET BEEN COMPLETED

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The

parties

have

been

working

Defendant

is

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Plaintiff’s

medical

records,

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predating the subject accident from an accident which Defendant

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just recently became aware of and that are highly relevant to

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this

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such,

Defendant

the

process

including

has

found

of

complete

discovery.

As

in

to

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case.

still

diligently

numerous

it

obtaining
records

difficult

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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)

to

Case 2:18-cv-00827-JAD-PAL Document 11 Filed 08/17/18 Page 3 of 4

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properly

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Plaintiff’s

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exchanging disclosures and authorizations, but obtaining records

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has been slow going.

hire

an

expert

injuries.

to

opine

Parties

as

have

to

the

been

causation

of

cooperative

in

complete the remaining discovery noted.

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HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

of pending discovery deadlines as additional time is needed to

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2400 W. HORIZON RIDGE PARKWAY

At this time, the parties seek a ninety (90) day extension

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RANALLI ZANIEL FOWLER & MORAN, LLC

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PROPOSED SCHEDULE OF DISCOVERY

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The parties hereby stipulate to continue the Discovery as
follows:
Current Deadline

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Proposed

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Last Day to Amend Pleadings:

08/15/18

11/13/18

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Initial Expert Disclosures:

09/14/18

12/13/18

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Interim Status Report:

09/14/18

12/13/18

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Rebuttal Expert Disclosures:

10/14/18

01/13/19

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Discovery Deadline:

11/13/18

02/11/19

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Dispositive Motion Deadline:

12/12/18

03/12/19

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Joint Pre-Trial Order:

01/11/19

04/11/19

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/ / /

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/ / /

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/ / /

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/ / /

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/ / /

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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)

Case 2:18-cv-00827-JAD-PAL Document 11 Filed 08/17/18 Page 4 of 4

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SAID DISCOVERY REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY
DELAYING DISCOVERY OR TRIAL OF THIS MATTER

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Bernstein & Poisson

RANALLI ZANIEL FOWLER & MORAN, LLC

Dated: August 17, 2018

Dated: August 17, 2018

/s/ Jamie H. Corcoran, Esq.
Scott L. Poisson, Esq.
Nevada Bar No.: 10188
Jamie H Corcoran, Esq.
Nevada Bar No.: 11790
320 South Jones Blvd
Las Vegas, Nevada 89107
Attorneys for Plaintiff
DARVIS LEWIS

/s/ Michael G. Trippiedi, Esq.
JAMES F. HOLTZ, ESQ.
Nevada Bar No. 8119
MICHAEL G. TRIPPIEDI, ESQ.
Nevada Bar No. 13973
2400 W. Horizon Ridge Parkway
Henderson, Nevada 89052
Attorneys for Defendant
WALGREEN CO.

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HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

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ORDER

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IT IS SO ORDERED:
Dated:

August 21, 2018
_________________
_____________________________
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)