United States District Court, D. Nevada
BIGHORN LAW SIRIAL. GUTIERREZ JACQUELINE R, BRETELL, ESQ,
SIRIA L, GUTIERREZ, ESQ. Attorneys for Plaintiff.
CANNON, GORMLEY ANGULO & STOBERSKI WALTER R. CANNON, ESQ,
Attorney for Defendants.
STIPULATION AND ORDER TO EXTEND DISCOVERY CUTOFF
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:
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.
DISCOVERY COMPLETED TO DATE
July 28, 2017, Defendants filed a Petition for Removal of
August 11, 2017, Defendant filed a Compliance with Court
Order Concerning Removal.
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
October 12, 2017, this Honorable Court granted the Discovery
Plan and Scheduling Order.
October 16, 2017, Defendants served Interrogatories and
Request for Production upon the Plaintiff.
October 26, 2017, Plaintiff served Interrogatories, Request
for Production of Documents, and Requests for Admissions upon
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