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.

Martin v. Target Corp.

United States District Court, D. Nevada

December 20, 2017

REBECCA MARTIN, an Individual; Plaintiff,
v.
TARGET CORPORATION, a Foreign Corporation; YET UNKNOWN EMPLOYEE; DOES I through X, inclusive, Defendants.

          WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Kym S. Cushing, Douglas M. Rowan Attorneys for defendant Target Corporation.

          THE GALLIHER LAW FIRM BY: Keith E. Galliher, Jr. Attorney for plaintiff Rebecca Martin.

          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 October 10, 2017, the parties held an initial Rule 26(f) Conference. Defendant served its initial disclosure of witnesses and documents on October 12, 2017. Plaintiff served her initial disclosure of witnesses and documents on October 10, 2017. On October 17, 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 20, 2017 and responses to the Requests for Production of Documents on November 28, 2017. On October 30, 2017, plaintiff propounded a First Set of Requests for Production of Documents upon defendant. Plaintiff has granted defendant an extension to respond to those written discovery requests. On November 22, 2017, plaintiff propounded a Second Set of Requests for Production of Documents upon defendant.

         On November 22, 2017, plaintiff noticed the deposition of one of defendant's current employees and the deposition of one of defendant's former employees for February 6, 2018.

         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 is still obtaining plaintiff's medical records through authorizations provided by plaintiff. Defendant needs to conduct the deposition of plaintiff and possibly four of plaintiff's treating healthcare providers once defendant has received plaintiff's medical records directly from the providers. Additionally, plaintiff suffered a prior injury at work, and defendant may seek to depose any healthcare providers who provided treatment for that injury once defendant obtains the medical records regarding that treatment. Plaintiff continues to experience symptoms she attributes to the subject incident so defendant may seek to have plaintiff appear for a Rule 35 Examination. Defendant needs to respond to plaintiff's written discovery requests.

         Plaintiff has scheduled the deposition of one of defendant's former and one of defendant's current employees and may conduct the depositions of additional employees and representatives. 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 prior and current treating healthcare providers. Defendant also needs to obtain those records and films to provide to defendant's medical expert. Also, plaintiff continues to experience symptoms she attributes to the subject incident, and defendant may seek to have her appear for a Rule 35 Examination. All of this discovery cannot be completed and provided to expert witnesses to allow them to complete expert reports prior to the current initial expert disclosure deadline. Accordingly, the parties request a sixty day extension of the current discovery deadlines.

         D. PROPOSED ...


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.