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Johnson v. Costco Wholesale Corp.

United States District Court, D. Nevada

April 20, 2018

CATHERINE JOHNSON, Plaintiff,
v.
COSTCO WHOLESALE CORPORATION, a Foreign Corporation; DOES I-X, and ROE ENTITIES I-X, inclusive, Defendants.

          Jorge A. Ramirez, Mark C. Severino, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, Attorneys for defendant Costco Wholesale Corporation.

          Lawrence M. Ruiz, Esq. Attorneys for Plaintiff.

          JOINT MOTION/STIPULATION AND ORDER TO CONTINUE DISCOVERY AND PRETRIAL DEADLINES (SECOND REQUEST)

         The above named parties, by and through their respective counsel of record, hereby move the court and submit the following STIPULATION/JOINT MOTION FOR EXTENSION OF DISCOVERY DEADLINES (First Request).

         A. DISCOVERY COMPLETED TO DATE

         1. On November 13, 2017, the parties held an initial rule 26(f) conference.

         2. Costco served its Rule 26 Initial Disclosures on November 30, 2017.

         3. Plaintiff served her initial disclosures on February 5, 2018.

         4. On or about December 8, 2017, Costco propounded its first sets of Interrogatories, Document Requests, and Requests for Admissions onto the Plaintiff. Plaintiff provided responses to Costco's Requests for Admissions on January 10, 2018. Thereafter, plaintiff provided responses to Costco's Interrogatories and Document Requests on February 6, 2018.

         5. On February 5, 2018, plaintiff served Costco with Interrogatories and Document Requests. Costco served it responses on April 19, 2018.

         6. Plaintiff was deposed on February 27, 2018.

         B. DISCOVERY THAT REMAINS TO BE COMPLETED

         1. Deposition of plaintiff's treating physicians and/or anticipated medical experts.

         2. Deposition of Costco's person most knowledgeable.

         3. Possible deposition of ...


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