United States District Court, D. Nevada
BRISBIOS BISGAARD & SMITH LLP BLAKE A. DOERR, ESQ.
Attorneys for Defendant Verizon Wireless
DEFENDANTS' MOTION TO EXTEND DISCOVERY
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.
OF POINTS AND AUTHORITIES
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
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.
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.
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.
DISCOVERY COMPLETED TO DATE
Parties conducted the Rule 26(f) meeting.
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.
DISCOVERY REMAINING TO BE COMPLETED
Plaintiff may choose to propound written discovery on the
Defendants will depose the Plaintiff's husband who was