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

United States District Court, D. Nevada

March 30, 2018

MARIANA OLAVARRE, Plaintiff,
v.
SMITH'S FOOD & DRUG CENTERS, INC.; DOES I-X, inclusive, and ROE CORPORATIONS I-X, inclusive, Defendants.

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

          DE CASTOVERDE LAW GROUP, DAVID MENOCAL, ESQ., Nevada Bar No. 0013191, Attorneys for Plaintiff, MARIANA OLAVARRE.

          COOPER 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 REQUEST)

         WHEREAS, 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

         IT IS 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.

         A. STATEMENT SPECIFYING THE DISCOVERY THAT HAS BEEN COMPLETED.

         1. The parties participated in the Fed.R.Civ.P. 26(f) conference;

         2. Both parties have made their disclosures pursuant to Fed.R.Civ.P. 26.1(a)(1).

         3. Both parties have served and responded to written discovery including interrogatories, requests for admissions, and requests for production of documents.

         4. Plaintiff and Defendant have collected all of Plaintiff's medical records.

         5. Defendant has deposed Plaintiff.

         6. 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 30(b)(6) deposition.

         7. Plaintiff has conducted co-efficient of friction testing at the SMITH'S store where the subject incident occurred.

         B. SPECIFIC DESCRIPTION OF THE DISCOVERY THAT ...


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