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Kim v. Verizon Wireless Vaw LLC

United States District Court, D. Nevada

June 28, 2017

SOO YOUNG KIM, Plaintiff,
v.
VERIZON WIRELESS VAW LLC, a Foreign Limited-Liability Company; VERIZON WIRELESS NETWORK PROCUREMENT LP, a Foreign Limited Partnership; VERIZON WIRELESS SERVICE, LLC, a Foreign Limited Liability Company; DOES I through X; and ROES I through X, inclusive, Defendant.

          LEWIS BRISBIOS BISGAARD & SMITH LLP BLAKE A. DOERR, ESQ. Attorneys for Defendant Verizon Wireless

          DEFENDANTS' MOTION TO EXTEND DISCOVERY DEADLINES

         COMES NOW, Defendants VERIZON WIRELESS (VAW) LLC, VERIZON WIRELESS NETWORK PROCUREMENT LP and VERIZON WIRELESS SERVICES, LLC (hereinafter collectively, VERIZON WIRELESS) by and through counsel of record LEWIS, BRISBOIS, BISGAARD & SMITH LLP and hereby submits its Motion to Extend Discovery Deadlines pursuant to Local Rule 26-4. The undersigned communicated with Plaintiff's counsel in an attempt to stipulate to the continuance but Plaintiff's counsel had not responded prior to the time for the timely filing of this motion therefore the continuance is being made via this motion.

         MEMORANDUM OF POINTS AND AUTHORITIES

         This discovery cutoff in this matter is September 11, 2017. The next discovery deadline in this matter is Initial Expert Disclosures on July 13, 2017. Accordingly this motion is being made 21 days before that deadline and is therefore timely.

         This request is being made because of the Defendant's recent filing of a Motion for Leave to File a Third-Party Complaint naming the party who installed the carpet at the Verizon retail location where the Plaintiff alleges she tripped. At her deposition, which was held on June 7, 2017, the Plaintiff testified that she tripped on carpet the was improperly installed or placed. Accordingly the Defendant sought leave of court to name the carpet installer as a third-party defendant. That motion is pending in this court.

         The parties were able to confer regarding this continuance but were unable to formalize a stipulation prior to the time this motion needed to be filed.

         Good cause exists for the requested continuance because the Defendants are seeking to avoid unnecessary costs and duplicative efforts of all parties given that its timely motion for leave to add a party has not been ruled upon.

         A. DISCOVERY COMPLETED TO DATE

         1. The Parties conducted the Rule 26(f) meeting.

         2. The Parties exchanged their Initial Disclosures Pursuant to FRCP. 26(a)(1); 3. The Defendant has procured the medical records of the Plaintiff; 4. The Defendant propounded written discovery on the Plaintiff which the Plaintiff responded to; 5. The Defendant deposed the Plaintiff on June 7, 2017.

         B. DISCOVERY REMAINING TO BE COMPLETED

         1. Plaintiff may choose to propound written discovery on the Defendant;

         2. The Defendants will depose the Plaintiff's husband who was present ...


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