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Taylor v. Target Corp.

United States District Court, D. Nevada

December 12, 2017

Nita Taylor, individually; Plaintiff,
v.
Target Corporation; and DOES 1 through 100; and ROE CORPORATIONS 101 through 200, Defendants.

          WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Kym S. Cushing Nevada Bar No. 004242 Douglas M. Rowan Nevada Bar No. 004736 Attorneys for defendant Target Corporation.

          BERNSTEIN & POISSON Scott L. Poisson Nevada Bar No. 010188 Erik A. Bromson Nevada Bar No. 009986 Attorney for plaintiff Nita Taylor.

          STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (FIRST REQUEST)

         The above named parties, by and through their respective counsel of record, hereby submit the following STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (First Request).

         A. DISCOVERY COMPLETED TO DATE

         This matter involves a slip and fall at one of Defendant's stores. On September 29, 2017, the parties held an initial Rule 26(f) Conference. Defendant served its initial disclosure of witnesses and documents on September 28, 2017. Plaintiff served her initial disclosure of witnesses and documents on September 29, 2017. On October 12, 2017, the Court entered a Stipulated Discovery Plan/Scheduling Order.

         On October 17, 2017, Defendant propounded a First Set of Interrogatories and First Set of Requests for Production of Documents upon Plaintiff. Plaintiff served her responses to the Interrogatories on November 15, 2017 and responses to the Requests for Production of Documents on November 22, 2017. On October 12, 2017, Plaintiff propounded a First Set of Interrogatories and First Set of Requests for Production of Documents upon Defendant. Plaintiff has granted Defendant an extension to respond to those written discovery requests.

         Defendant has requested Plaintiff's medical records and films directly from her medical providers through records authorizations provided by Plaintiff.

         B. DISCOVERY THAT REMAINS TO BE COMPLETED

         Defendant still needs to respond to Plaintiff's written discovery requests. Defendant is still obtaining Plaintiff's medical records through authorizations provided by Plaintiff. Defendant needs to conduct the deposition of Plaintiff and at least three of Plaintiff's treating healthcare providers once Defendant has received Plaintiff's medical records directly from the providers. Plaintiff continues to experience symptoms she attributes to the subject incident and anticipates requiring future treatment so Defendant believes it is premature to conduct some of those depositions. Defendant may seek to have Plaintiff appear for a Rule 35 Examination.

         Plaintiff anticipates conducting the depositions of Defendant's employees. The parties also anticipate designating expert witnesses and conducting the depositions of any designated expert witnesses.

         C. REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED

         Defendant is still in the process of obtaining Plaintiff's medical records and films. Defendant needs to obtain those records before conducting the depositions of Plaintiff and her treating healthcare providers. Defendant also needs to obtain those records and films to provide to Defendant's medical expert.

         The parties have discussed the possibility of early resolution of this matter, including the potential scheduling of mediation. The parties would like to limit their expenses and conduct mediation prior to engaging in further discovery, including the disclosure of expert witnesses. The parties cannot schedule and conduct mediation, conduct additional discovery, and obtain reports from expert witnesses prior to the current deadline for the disclosure of expert witnesses. Accordingly, the parties request a sixty day extension of the current discovery deadlines.

         D. PROPOSED ...


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