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Allen v. Target Corp.

United States District Court, D. Nevada

January 29, 2018

ANGELA ALLEN, individually, Plaintiff,
v.
TARGET CORPORATION, a Foreign Corporation; DOES I - X, inclusive; and ROE CORPORATIONS I - X, inclusive, 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

          MAINOR WIRTH, LLP Bradley S. Mainor Nevada Bar No. 007434 Joseph J. Wirth Nevada Bar No. 010280 Attorney for plaintiff Angela Allen

          STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (SECOND REQUEST)

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

         A. DISCOVERY COMPLETED TO DATE

         This matter involves a slip and fall at one of Defendant's stores. On September 20, 2017, the parties held an initial Rule 26(f) Conference. Defendant served its initial disclosure of witnesses and documents on September 18, 2017. Plaintiff served her initial disclosure of witnesses and documents on September 21, 2017. Plaintiff served her first supplemental disclosure of witnesses and documents on October 2, 2017. On September 27, 2017, the Court entered a Stipulated Discovery Plan/Scheduling Order. On November 29, 2017, the Court granted the parties' first stipulated request to extend discovery deadlines.

         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 those written discovery requests on November 20, 2017. On January 25, 2018, Plaintiff propounded a First Set of Interrogatories and First Set of Requests for Production of Documents upon Defendant.

         On November 9, 2017, Plaintiff noticed the depositions of three of Defendant's current employees and the deposition of one of Defendant's former employees for November 28, 2017. Due to the length of the depositions, the parties were only able to complete the deposition of the former employee and one of the current employees on November 28. Plaintiff has re-noticed the other two depositions for February 8, 2018. The parties are also working to schedule additional depositions of Defendant's former and current employees.

         Defendant has requested Plaintiff's medical records and films directly from her medical providers through records authorizations provided by Plaintiff. Defendant has received some, but not all, of the requested records and films.

         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, a witness who was with her at the time of the subject incident, and at least two 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 may seek to have Plaintiff appear for a Rule 35 Examination. Defendant will respond to Plaintiff's written discovery requests.

         Plaintiff will conduct the two depositions of Defendant's current employees and intends to 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 treating healthcare providers. Defendant also needs to obtain those records and films to provide to Defendant's medical expert. Also, as Plaintiff continues to experience symptoms she attributes to the subject incident and anticipates requiring future treatment, Defendant will likely seek to have Plaintiff attend a Rule 35 Examination.

         Plaintiff needs to conduct the depositions of Defendant's employees prior to the disclosure of expert witnesses. Defendant's employees had limited availability for ...


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