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Robinson v. MV Transportation, Inc.

United States District Court, D. Nevada

March 21, 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. PARTY DISCLOSURE DATE SERVED PROPOUNDED BY DATE SERVED DOCUMENT PROPOUNDED UPON DATE RESPONDED PARTY DISCLOSURE DATE SERVED DEPONENT DATE OF DEPOSITION Event Current Schedule Proposed Schedule Event Current Schedule Proposed Schedule

          WOOD, SMITH, HENNING & BERMAN, LLP BROOKE A. BOHLKE, ESQ. Nevada Bar No. 9374 ANALISE N. MARTINEZ, ESQ. Nevada Bar No. 13185 Attorneys for Defendant, MV Transportation, Inc.

          RICHARD HARRIS LAW FIRM JOHNATHAN LEAVITT, ESQ. Nevada Bar No. 13172 Attorney for Plaintiff, Tonie Robinson

          STIPULATION AND REQUEST TO EXTEND DISCOVERY DEADLINE (FOURTH REQUEST)

         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 forty-six (46) days until June 26, 2018 for the sole purpose of taking the depositions of Plaintiff's Expert, Dr. Jason Garber, and extending the dispositive motion deadline as follows:

         I. STATEMENT OFFACTS

         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 again stipulated to extend discovery on February 2, 2018 in light of expert unavailability, newly disclosed witness depositions, and the necessity of obtaining records for newly disclosed medical providers.

         The parties have been working together and coordinating discovery requests to ensure all discovery is timely completed. However, Plaintiff recently communicated that her treating physician and expert, Dr. Garber had a family emergency and would not be able to attend his noticed March 8, 2018 deposition. Dr. Garber also indicated that he did not have availability until May 2018 for his deposition. As a result, the parties requested an extension of the deadline by forty-five (45) days until May 11, 2018. Recently the Parties were advised that Dr. Garber will not be available for deposition until June 26, 2018. As a result, the parties request an extension of the deadline by forty-six (46) days until June 26, 2018 for the limited purpose of taking Dr. Garber's deposition.

         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
DISCLOSURE
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
7th Supplement
January 18, 2018
8th Supplement
January 18, 2018
9th Supplement
January 25, 2018
10th Supplement
February 21, 2018
11th Supplement
February 27, 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
February 12, 2018

         The parties have also complied with expert disclosure deadlines:

PARTY
DISCLOSURE
DATE SERVED
Plaintiff
Initial
August 29, 2017
Defendant
Initial
September 28, 2017
1st Supplement
November 27, 2017
2nd Supplement
December 4, 2017

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