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Heath v. Tristar Products, Inc.

United States District Court, D. Nevada

May 8, 2018

TAWNDRA L. HEATH, an individual, Plaintiff,
v.
TRISTAR PRODUCTS, INC., a Pennsylvania corporation; ZHONGSHAN JINGUANG HOUSEHOLD APPLIANCE MANUFACTURE CO., LTD, a foreign corporation; DOE Individuals 1-10; and ROE Corporations 11-20; Defendant.

          COGBURN LAW OFFICES Jamie S. Cogburn, Esq. Nevada Bar No. 8409 Joshua A. Dowling, Esq.Attorneys for Plaintiff

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Plaintiff, Tawndra L. Heath, by and through her counsel, Jamie S. Cogburn, Esq. and Joshua A. Dowling, Esq. of Cogburn Law Offices, and Tristar Products, Inc., by and through their counsel, Alexandria L. Layton, Esq. of Snell & Wilmer, LLP, hereby stipulate and agree as follows:

         1. NATURE OF THE ACTION

         This is an action for personal injuries arising from an incident occurring on December 29, 2016. Plaintiff alleges Defendants designed, manufactured, sold and distributed a pressure cooker, Power Pressure Cooker XL, Model No. PPC77O, online from the Power Pressure Cooker XL website, http://www.powerpressurecooker.com/, on November 20, 2014. Plaintiff further alleges the subject pressure cooker reached her, without substantial change in its condition. On December 29, 2016, Plaintiff alleges the pressure cooker exploded due to a product defect and/or Defendants' negligence. As a result of the subject incident, Plaintiff claims severe injuries and damages which are permanent in nature.

         2. DISCOVERY THAT HAS BEEN COMPLETED

         The parties have exchanged FRCP 26(f) disclosures of documentary evidence and witnesses, inclusive of Plaintiffs treatment records. In addition, the parties have completed the following written discovery and depositions:

         i. Plaintiff, Tawndra Heath

         a. Plaintiffs Requests for Production of Documents; and, b. Defendant, Tristar Products, Inc. Responded.

         ii. Defendant, Tristar Products, Inc.

         a. Defendant's Proposed Protective Order

         3. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED

         i. Plaintiff, Tawndra Heath

         a. Deposition of Defendant, Tristar Products, Inc.'s Corporate Representative(s);

         b. Deposition of Defendant, Zhongshan Jinguang Household Appliance Manufacture Co., ...


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