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.

Robinson v. MV Transportation, Inc.

United States District Court, D. Nevada

February 2, 2018

TONIE ROBINSON, individually, Plaintiff,
v.
MV TRANSPORTATION, INC.; DOE BUS OPERATOR; DOE BUS DRIVER; DOES I-X, and ROE CORPORATIONS I-X, inclusive, Defendants.

          WOOD, SMITH, HENNING & BERMAN, LLP BROOKE A. BOHLKE, ESQ. ANALISE N. MARTINEZ, ESQ. Attorneys for Defendant, MV Transportation, Inc.

          RICHARD HARRIS LAW FIRM DAVID J. MARTIN, ESQ. Attorney for Plaintiff, Tonie Robinson

          STIPULATION AND REQUEST TO EXTEND DISCOVERY DEADLINES

          PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE.

         In accordance with the Federal Rules of Civil Procedure and Local Rule 26-4, Plaintiff Tonie Robinson ("Plaintiff) and Defendant MV Transportation, Inc. ("MV") hereby stipulate and agree to and jointly move this Honorable Court for an Order extending the discovery cut-off by sixty (60) days for the sole purpose of taking depositions and obtaining medical records and the dispositive motion deadline as follows:

         I. STATEMENT OF FACTS

         This case arises out of an alleged incident that occurred on November 2, 2015, while Plaintiff was a passenger of a bus operated by MV. According to the Complaint, Plaintiff, Tonie Robinson, was a passenger on a bus and sustained injuries as a result of the bus driver failing to properly secure her three-wheel motorized scooter prior to driving and making an erratic turn at an unsafe speed, causing Plaintiff to fall out of her chair onto the floor.

         After the matter was removed to federal court, the parties engaged in an FRCP 26 conference with timely submission of a joint proposed scheduling order that complied with the rules. Due to the extensive medical treatment and disclosure of significant pre-existing conditions by Plaintiff, the parties stipulated to extend discovery on September 21, 2017. As a result of this initial stipulation, significant progress towards completing discovery in this matter has occurred.

         The parties have been working together and coordinating discovery requests to ensure all discovery is timely completed. However, Plaintiff was recently deposed and provided numerous additional doctors from whom she received treatment and provided address for several witnesses whose depositions were previously noticed. MV also timely noticed the depositions of Plaintiffs experts, Dr. Jason Garber and Dr. Lanzkowsky, however, both doctors are not available to be deposed until March, 2018. Plaintiff also recently provided topics for an FRCP 30(b)(6) deposition, which the parties have agreed will occur on February 13, 2018. As a result, the parties request an extension of the deadline by sixty (60) days to March 27, 2018 for completing discovery for the limited purpose of obtaining medical records from newly disclosed providers and taking the depositions of Mr. Arthur Adams, Mr. George Spears, Dr. Garber, Dr. Lanzkowsky, and Defendant's FRCP 30(b)(6) deponent.

         II. DISCOVERY COMPLETED:

         The parties have been able to complete a significant amount of discovery to date. In this time period, the parties have participated in the Early Case Conference pursuant to FRCP 26. After discovery opened, each side began to deposit their disclosures. As to Rule 26 disclosures:

PARTY

DISCLOSUREI

DATE SERVED

Plaintiff

Initial

August 21, 2017

1st Supplement

September 13, 2017

2nd Supplement

December 15, 2017

Defendant

Initial

August 11, 2017

1st Supplement

October 6, 2017

2nd Supplement

October 13, 2017

3rd Supplement

October 17, 2017

4th Supplement

December 1, 2017

5th Supplement

December 21, 2017

6th Supplement

January 12, 2018

         The parties have also been able to make considerable progress with respect to written discovery:

PROPOUNDED BY

DATE SERVED

DOCUMENT

PROPOUNDED UPON

DATE RESPONDED

Plaintiff

August 8, 2017

First Set of Interrogatories

Defendant

September 14, 2017

August 8, 2017

First Set of Request for Production of Documents

Defendant

September 14, 2017

Defendant

August 11, 2017

First Set of Interrogatories

Plaintiff

September 14, 2017

August 11, 2017

First Set of Request for Production of Documents

Plaintiff

September 14, 2017

August 11, 2017

First Set of Request for Admissions

Plaintiff

September 13, 2017

September 28, 2017

Second Set of Request for Production of Documents

Plaintiff

November 6, 2017

November 9, 2017

Third Set of Request for Production of Documents

Plaintiff

December 12, 2017

January 18, 2018

Fourth Set of Request for Production for Documents

Plaintiff


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.