United States District Court, D. Nevada
S. BUSBY, Nevada Bar #001107, COOPER LEVENSON, P.A.,
Attorneys for Defendant, SMITH'S FOOD & DRUG CENTERS,
CASTOVERDE LAW GROUP, DAVID MENOCAL, ESQ., Nevada Bar No.
0013191, Attorneys for Plaintiff, MARIANA OLAVARRE.
LEVENSON, PA., JERRY S. BUSBY, ESQ., Nevada Bar No. 001107,
1835 Village Center Circle, Attorneys for Defendant,
SMITH'S FOOD & DRUG CENTERS, INC.
STIPULATION TO EXTEND DISCOVERY SCHEDULE (SECOND
the parties have diligently conducted discovery, but an
extension of 45-days is required to complete all of the
outstanding discovery needed to have the case ready for trial
HEREBY STIPULATED AND AGREED by and between ALEX DE
CASTROVERDE, ESQ. of DE CASTROVERDE LAW GROUP, Attorneys for
Plaintiff MARIANA OLAVARRE, and JERRY S. BUSBY, ESQ. of the
law firm COOPER LEVENSON, P.A., Attorneys for Defendant
SMITH'S FOOD & DRUG CENTERS, INC. that all discovery
deadlines in this matter be continued for a period of 45 days
to allow Defendant to take the depositions of Maria Horta and
Mariana Ramirez, Plaintiff to take a Rule 30(b)(6)
deposition, and for the parties to disclose expert witnesses.
STATEMENT SPECIFYING THE DISCOVERY THAT HAS BEEN
parties participated in the Fed.R.Civ.P. 26(f) conference;
parties have made their disclosures pursuant to Fed.R.Civ.P.
parties have served and responded to written discovery
including interrogatories, requests for admissions, and
requests for production of documents.
Plaintiff and Defendant have collected all of Plaintiff's
Defendant has deposed Plaintiff.
Plaintiff has deposed the following SMITH'S employee
witnesses: David Hahn, Thomas Watanaba and Dorothy
Goettelmann. Plaintiff is in the process of noticing a Rule
Plaintiff has conducted co-efficient of friction testing at
the SMITH'S store where the subject incident occurred.
SPECIFIC DESCRIPTION OF THE DISCOVERY THAT ...