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.

Smith v. Smith's Food & Drug Centers, Inc.

United States District Court, D. Nevada

March 26, 2018

ANTONIO SMITH, an individual, Plaintiff,
v.
SMITH'S FOOD & DRUG CENTERS, INC.; DOES 1 through 100; and ROE CORPORATION 101 through 200, inclusive, Defendant(s).

          BERNSTEIN & POISSON KARLAM. GABOUR, ESQ. Nevada Bar #13123 Attorneys for Plaintiff ANTONIO SMITH

          COOPER LEVENSON, P.A. JERRY S. BUSBY, ESQ. Nevada Bar #001107 Attorneys for Defendant SMITH'S FOOD & DRUG CENTERS, INC.

          STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST)

         WHEREAS, the parties participated in the FRCP Rule 26(f) conference and thereafter exchanged their respective disclosure statements in a timely manner and have begun discovery; and

         WHEREAS, Defendant is scheduled take Plaintiffs deposition on April 10, 2018, and Plaintiff is in the process of scheduling the depositions of Defendant's employees and/or knowledgeable representative/s; and

         WHEREAS, the parties have been cooperating in discovery but have encountered unexpected problems that have caused delays in responding to written discovery, taking depositions and gathering all of the medical records relevant to Plaintiffs claim for damages; and

         WHEREAS, the parties intend to identify and disclose expert witnesses but will need additional time to do so as the parties are still gathering the requisite foundational evidence needed by the experts to provide their expert opinions; and

         WHEREAS, counsel for the parties previously discussed and agreed to extend discovery to allow the parties to complete the same. Unfortunately, due to scheduling conflicts and other obligations, counsel were unable to finalize and submit this stipulation earlier;

         IT IS HEREBY STIPULATED AND AGREED by and between KARLA M. GABOUR, ESQ. of the law firm BERNSTEIN & POISSON, Attorneys for Plaintiff ANTONIO SMITH, and JERRY S. BUSBY, ESQ. of the law firm COOPER LEVENSON, P. A., Attorneys for Defendant SMITH'S FOOD & DRUG CENTERS, INC. that certain discovery deadlines in this matter be continued for a period of 45 days to provide additional time for counsel for the parties to retain and disclose expert witnesses.

         A. STATEMENT SPECIFYING THE DISCOVERY THAT HAS BEEN COMPLETED.

         1. The parties participated in the Fed.R.Civ.P. 26(f) conference on December 12, 2017.

         2. Both parties made their initial disclosures of evidence pursuant to Fed.R.Civ.P. 26.1 (a)(1) in a timely fashion.

         3. Plaintiff is finalizing written discovery to serve on Defendant.

         4. Defendant served interrogatories, requests for admissions, and requests for production of documents and Plaintiff responded to the same after being granted two extensions.

         5. Defendant has requested and recently received HIPAA authorizations from Plaintiffs attorney and has sent document requests to the medical providers identified by Plaintiff (approximately ten providers). In addition, Defendant has identified other medical providers and has sent a request to Plaintiffs attorney to provide authorizations for the same. As a result, Defendant anticipates receiving medical records within the next thirty days from the providers identified by Plaintiff. Defendant will need additional time to recover records from the additional providers identified and for whom HIPAA authorizations have been requested but not yet received, 6. Defendant has scheduled the Plaintiffs deposition to take place on April 10, 2018. (Defendant desired ...


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.