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Kaups v. Lowe's Home Centers, LLC

United States District Court, D. Nevada

July 2, 2018

AILI KAUPS, Plaintiff,
v.
LOWE'S HOME CENTERS, LLC, LOWE'S HIW, INC., DOE MAINTENANCE EMPLOYEE, DOE EMPLOYEE, DOE JANITORIAL EMPLOYER, DOE OWNER, I-V, ROE OWNERS, ROE EMPLOYER, ROE COMPANY and ROE COMPANIES, I-V, Defendants.

          BIGHORN LAW SIRIAL. GUTIERREZ JACQUELINE R, BRETELL, ESQ, SIRIA L, GUTIERREZ, ESQ. Attorneys for Plaintiff.

          OLSON, CANNON, GORMLEY ANGULO & STOBERSKI WALTER R. CANNON, ESQ, Attorney for Defendants.

          STIPULATION AND ORDER TO EXTEND DISCOVERY CUTOFF (THIRD REQUEST)

         COMES NOW, Plaintiff, AILI KAUPS, by and through her attorney, JACQUELINE R. BRETELL, ESQ., of BIGHORN LAW, and Defendant, LOWE'S HOME CENTERS, LLC and LOWE'S HIW, INC., by and through its attorney, WALTER R, CANNON, ESQ., of OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI, and hereby stipulate, agree and make this joint application to extend the discovery cutoff date, for a period of seventy-seven (77) days, from July 23, 2018, to and including October 8, 2018, This Stipulation is made and based upon the following facts and for the following reasons:

         I. NTRODUCTION

         This action arises out of an alleged incident that occurred on April 10, 2015 in the parking lot area of the Lowe's store located at 9955 South Eastern Avenue, Las Vegas, Nevada, 89183. In her Complaint, Plaintiff alleges that she slipped and fell over a rock, pine cone, or a crack in the parking lot as she was walking to her vehicle, causing her to fall to the ground and injure herself. Further, Plaintiff alleges general complaints of pain in her cervical and lumbar areas, a non-displaced fracture in her right knee and left ankle, and a partially torn rotator cuff which required orthoscopie surgery to repair. Defendant's Answer denies fault for the accident and affirmatively alleges that Plaintiffs claimed injuries were not all related to the fall that she has alleged to have experienced.

         II. DISCOVERY COMPLETED TO DATE

         1. On July 28, 2017, Defendants filed a Petition for Removal of Civil Action.

         2. On August 11, 2017, Defendant filed a Compliance with Court Order Concerning Removal.

         3. On August 28, 2017, the parties filed a Joint Status Report Concerning Removal, 4. On October 10, 2017, the parties submitted a proposed Discovery Plan and Scheduling Order to the Court.

         5. On October 12, 2017, this Honorable Court granted the Discovery Plan and Scheduling Order.

         6. On October 16, 2017, Defendants served Interrogatories and Request for Production upon the Plaintiff.

         7. On October 26, 2017, Plaintiff served Interrogatories, Request for Production of Documents, and Requests for Admissions upon Defendants.

         8. On December 8, 2017, Plaintiff served Responses to Defendant's First Set of Requests for Production of Documents upon Defendants, 9. On December 8, 2017, Plaintiff served ...


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