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Allen v. Target Corp.

United States District Court, D. Nevada

July 16, 2018

ANGELA ALLEN, individually; Plaintiff,
v.
TARGET CORPORATION, a Foreign Corporation; DOES I - X, inclusive; and ROE CORPORATIONS I - X, inclusive, Defendants.

          MAINOR WIRTH, LLP JOSEPH J. WIRTH, ESQ. Counsel for Plaintiff.

          PERRY & WESTBROOK, P.C. ALAN W. WESTRBOOK, ESQ. Counsel for Defendant.

          STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (FIFTH REQUEST)

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

         A. DISCOVERY COMPLETED TO DATE

         This matter involves a slip and fall at one of Defendant's stores. On September 20, 2017, the parties held an initial Rule 26(f) Conference. On September 27, 2017, the Court entered a Stipulated Discovery Plan/Scheduling Order. On November 29, 2017, the Court granted the parties' first stipulated request to extend discovery deadlines. On January 29, 2018, the Court granted the parties' second stipulated request to extend discovery deadlines. On April 11, 2018, the Court granted the parties' third stipulated request to extend discovery deadlines. On June 7, 2018, the Court granted the parties' fourth stipulated request to extend discovery deadlines. On June 29, 2018, the Court granted a Substitution of Attorneys naming Alan W. Westbrook, Esq., of PERRY & WESTBROOK, as Defendant's new counsel of record.

         To date, Plaintiff has produced the following discovery:

• Plaintiff's Initial List of Witnesses and Production of Documents Pursuant to FRCP 26.1(a), served September 21, 2017;
• 1st Supplement to Plaintiff's Initial List of Witnesses and Production of Documents Pursuant to FRCP 26.1(a), served October 2, 2017;
• 2nd Supplement to Plaintiff's Initial List of Witnesses and Production of Documents Pursuant to FRCP 26.1(a), served November 17, 2017;
• Plaintiff's Answers to Defendant Target Corporation's First Set of Interrogatories, served November 20, 2017;
• Plaintiff's Responses to Defendant's First Set of Requests for Production of Documents, served November 20, 2017;
• 3rd Supplement to Plaintiff's Initial List of Witnesses and Production of Documents Pursuant to FRCP 26.1(a), served January 8, 2017;
• 4th Supplement to Plaintiff's Initial List of Witnesses and Production of Documents Pursuant to FRCP ...

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