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Picker v. Albertson's LLC

United States District Court, D. Nevada

November 27, 2017

NAJIA PICKER, individually, Plaintiff,
v.
ALBERTSON'S LLC; and DOES 1 through 100; and ROE CORPORATIONS 101 through 200, Defendants.

          BERNSTEIN & POISSON, LLC, SCOTT L. POISSON, ESQ, ERIK A. BROMSON, ESQ., Attorneys for Plaintiff, NAJIA PICKER,

          MORAN BRANDON BENDAVID MORAN, LEW BRANDON, JR., ESQ., KRIS D. KLINGENSMITH, ESQ., Attorneys for Defendant, ALBERTSONS, LLC

          STIPULATION AND ORDER FOR DISCOVERY PLAN AND SCHEDULING ORDER (SECOND REQUEST)

         Plaintiff, NAJIA PICKER, and Defendant, ALBERTSONS, LLC, by and through their undersigned attorneys, submit to the Court the following Stipulation and Order for Extension/Modification of the Discovery Plan and Scheduling Order pursuant to LR IA 6-1, LR 26-4 (a) and Court Order Document No. 13.

         I. Local Rule 6-1

         Under LR IA 6-1(a) every stipulation to extend time must inform the court of any previous extensions granted and state the reason for the extension requested.

         A. The Requirement of Local Rule 6-1 Are Satisfied

         This is the second request for extension filed by the parties. This extension is requested to allow Defendant to continue to compile Plaintiff's medical records both allegedly related to this matter's subject incident and her known pre-incident injuries and treatment. Additional time is needed to allow the parties to complete expert reports and for Defendant to potentially conduct FRCP 35 examinations. The Plaintiff has indicated that she will be conducting the FRCP 30(b)(6) deposition of Defendant's representative(s). Lastly, there remain at least one witness and employees that have yet to be deposed.

         II. Local Rule 26-4(a)

         Under LR 26-4 (a) a statement specifying the Discovery completed:

         Both Plaintiff and Defendant have exchanged their initial document and witness disclosures, with supplements thereto. Plaintiff has provided responses to Defendant's written discovery requests. Defendant has responded to Plaintiff's discovery requests. Defendant conducted the deposition of Plaintiff on September 22, 2017. Lastly, Defendant has begun to subpoena Plaintiff's various disclosed medical providers and is still awaiting responses from at least ten (10) of the Plaintiff's known treating providers. These providers include American Medical Response, Centennial Hills Hospital Medical Center, Advanced Orthopedics & Spine, Desert Radiologists, and several other providers. Defendant has received invoices from several of these providers and, despite providing payment and following up, has yet to receive a response.

         III. Local Rule 26-4(b)

         Under LR 26-4(b) a specific description of the Discovery that remains to be completed: The remaining Discovery to be completed includes initial and rebuttal expert disclosures, experts' depositions, depositions of Plaintiff's treating providers, and the depositions of Defendant's FRCP 30(b)(6) witness(es) and designated fact witnesses also remain to be completed. Lastly, Defendant is currently awaiting responses to subpoenas from at least ten (10) the Plaintiff's known treating providers. As noted above, Defendant received invoices and provided payment; however, Defendant has yet to receive records despite payment and following up with the providers. Lastly, Defendant may potentially request an FRCP Rule 35 exam upon receipt and confirmation of Plaintiff's relevant pre- and post-incident treatment history.

         IV. Local Rule 26-4(c)

         Under LR 26-4(c) the reasons why Discovery remaining was not completed within the ...


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