United States District Court, D. Nevada
LAW FIRM, Chu Ramzy P. Ladah, Esq. Nevada Bar No. 11405,
Joseph C. Chu, Esq. Nevada Bar No. 11082 Attorneys for
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, Jorge A.
Ramirez, Esq. Nevada Bar No. 6787 Mark C. Severino, Esq.
Nevada Bar No. 14114 Attorneys for defendant GGP Meadows
Mall, LLC d/b/a Meadows Mall
STIPULATION FOR EXTENSION OF DISCOVERY
above named parties, by and through their respective counsel
of record, hereby submit the following STIPULATION FOR
EXTENSION OF DISCOVERY DEADLINES (Second Request).
DISCOVERY COMPLETED TO DATE
matter involves a slip and fall at Defendant GGP Meadows
Mall. On October 18, 2017, the parties held an initial Rule
26(f) Conference. On November 3, 2017, the Court entered a
Stipulated Discovery Plan/Scheduling Order. Defendant served
its initial disclosure of witnesses and documents on November
10, 2017. Plaintiff served her initial disclosure of
witnesses and documents on November 2, 2017.
November 27, 2017, Plaintiff propounded a First Set of
Interrogatories and First Set of Requests for Production of
Documents upon Defendant. Defendant served its responses to
those written discovery requests on February 14, 2018. On
December 12, 2017, Defendant propounded a First Set of
Interrogatories, First Set of Requests for Admission and
First Set of Requests for Production of Documents upon
Plaintiff. Plaintiff served her responses to those written
discovery requests on February 8, 2018.
January 22, 2018, the Plaintiff served her first supplement
to his initial disclosures and made her initial expert
disclosures. Defendant made its initial expert disclosures on
that same date. On February 13, 2018, Defendant served its
first supplement to the initial disclosure of witnesses and
documents which included a surveillance video depicting the
incident. The parties took the deposition of Plaintiff on
February 22, 2018.
served its second supplement to its initial disclosures on
March 13, 2018. Thereafter, Defendant served its first
supplements to its expert disclosures on April 23, 2018, and
Defendant served it third supplement to its initial expert
disclosures on April 24, 2018. Plaintiff served her first
supplement to her expert disclosures and second supplement to
her initial disclosres on April 24, 2018 as well.
2, 2018, the Parties took the deposition of Defendant's
30(b)(6) witness. Defendant made its second supplemental
expert disclosures on May 14, 2018.
the parties have the following depositions noticed:
Plaintiff's Expert Thomas Dunn, MD: May 24, 2018
Plaintiff's Expert Thomas Jennings: May 29, 2018
Percipient witness Erik Khachatryan: June 4, 2018
Percipient Witness Pascual Hernandez: June ...