Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Brown v. Albertsons, LLC

United States District Court, D. Nevada

November 28, 2017

TAMECIA BROWN, Plaintiff,
v.
ALBERTSON'S LLC, a foreign limited liability company; DOES I through X; and ROE ENTITIES I through X, Defendants.

          TANNER LAW FIRM DAVID A. TANNER, ESQ. ATTORNEY FOR PLAINTIFF, TAMECIA BROWN

          MORAN BRANDON BENDAVID MORAN LEW BRANDON, JR., ESQ. JUSTIN W. SMERBER, ESQ. MATTHEW WHITTAKER, ESQ. ATTORNEYS FOR DEFENDANT, ALBERTSON'S, LLC

          STIPULATION AND ORDER FOR EXTENSION/MODIFICATION OF DISCOVERY PLAN AND SCHEDULING ORDER

         Plaintiff, TAMECIA BROWN, and Defendant, ALBERTSON'S, LLC, by and through its 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 fifth request for extension filed by the parties. This fifth extension comes at the direction of the Court following the hearing on Albertsons, LLC's Motion to Strike Plaintiffs Future Damages. In ruling upon said motion, the Court directed the parties to enter a stipulation to extend the discovery deadlines by 60 days from the date of the November 7, 2017 hearing so as to allow Albertsons, LLC to designate a spine expert for its case-in-chief, as well as to provide rebuttal opinions to Plaintiffs Expert's opinions regarding the need for future spine care. Accordingly, the parties are submitting this stipulation to continue the discovery deadlines.

         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 documents and witness disclosures, with supplements thereto. Plaintiff has provided responses to Defendant's written discovery requests on the following dates: Plaintiffs Responses to Defendant's First Set of Requests for Admissions, Plaintiffs Responses to Defendant's First Set of Requests for Production of Documents, and Plaintiffs Responses to Defendant's First Set of Request of Interrogatories all dated November 8, 2016. Subpoenas for Plaintiffs medical records were sent out November 17, 2016. Defendant has also responded to Plaintiffs discovery requests: Defendant's Responses to Plaintiffs First Set of Requests for Admissions dated November 1, 2016 and Defendant's Responses to Plaintiffs First Set of Requests for Production of Documents and Answers to Plaintiffs First Set of Interrogatories both dated November 8, 2016.

         Moreover, Plaintiff completed the deposition of Defendant employee, John Ryan Ramirez on November 8, 2016. Plaintiff also completed the deposition of Defendant's Person Most Knowledgeable on November 10, 2016. Further, Plaintiffs deposition was conducted on December 21, 2016. Plaintiffs medical records have been subpoenaed and continue to be subpoenaed as her care continues.

         The deposition of Plaintiff s Medical Expert, Dr. Nik Liu was completed on October 26, 2017. The deposition of Plaintiff s Medical Expert, Dr. Andrew Cash was partially completed on October 12, 2017 and is scheduled to be completed on November 30, 2017. The parties are continuing to complete expert depositions.

         III. Local Rule 26-4(b)

         Under LR 26-4(b) a specific description of the Discovery that ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.