Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Guiwan v. GGP Meadows Mall, LLC

United States District Court, D. Nevada

May 25, 2018

LYNN GUIWAN, individually, Plaintiff,
v.
GGP Meadows Mall, LLC, d/b/a MEADOWS MALL, a foreign Limited Liability Company; DOE EMPLOYEE; DOES BUSINESS ENTITIES I through XXX, inclusive, Defendants,

          LADAH LAW FIRM, Chu Ramzy P. Ladah, Esq. Nevada Bar No. 11405, Joseph C. Chu, Esq. Nevada Bar No. 11082 Attorneys for plaintiff

          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 DEADLINES

         The above named parties, by and through their respective counsel of record, hereby submit the following STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (Second Request).

         A. DISCOVERY COMPLETED TO DATE

         This 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.

         On 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.

         On 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.

         Defendant 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.

         On May 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.

         Currently, 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 ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.