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Ciccolella v. Smith's Food & Drug Centers, Inc.

United States District Court, D. Nevada

March 27, 2019

JANEY RUTH CICCOLELLA, individually, Plaintiff,
v.
SMITH'S FOOD & DRUG CENTERS, INC., a Foreign Corporation; THE KROGER CO., a Foreign Corporation; DOES I - X, and ROE CORPORATIONS I - X, inclusive, Defendants.

          CHRISTIAN Z. SMITH, ESQ. RICHARD HARRIS LAW FIRM Attorney for Plaintiff

          RICHARD HARRIS LAW FIRM CHRISTIAN Z. SMITH, ESQ. Attorneys for Plaintiff JANEY CICCOLELLA

          COOPER LEVENSON, P.A. JERRY S. BUSBY, ESQ. Attorneys for Defendant SMITH'S FOOD & DRUG CENTERS

          STIPULATION AND ORDER TO EXTEND DISCOVERY (THIRD REQUEST)

         1. The parties can show good cause for the present stipulation.

         Previously, counsel stipulated to a 60-day extension to discovery to allow the parties to complete discovery. One of the primary reasons for the prior stipulation was that Plaintiff's prior attorney, Elaine Marzola Esq., had experienced the loss of a family member which delayed discovery. Counsel resumed discovery; however, discovery was placed on hold because the parties agreed to conduct a private mediation with Judge Stewart Bell on March 6, 2019. Due to the scheduled mediation, the parties filed a second request to extend the discovery deadlines by 30-days in hopes that this matter would resolve at mediation. The parties attended the mediation on March 6, 2019; however, a settlement was not reached.

         After the March 6, 2019 mediation, Ms. Marzola left the Richard Harris Law Firm and Plaintiff's case was transferred within the law firm to Christian Z. Smith, Esq. A Notice of Appearance for Mr. Smith was filed on or about March 15, 2019. Mr. Smith has undertaken efforts to get up to speed on the litigation of this matter.

         Mr. Smith and Jerry Busby, Esq, Defendant's counsel, have had discussions about the discovery that needs to be completed which mainly involves obtaining all of Plaintiff's prior medical records. It was agreed that it will take more time to obtain these prior treatment records than previously contemplated because some of these medical providers are out of state. As such, the parties are requesting a 90-day extension.

         IT IS HEREBY STIPUALTED AND AGREED by and between CHRISTIAN Z. SMITH, ESQ. of the RICHARD HARRIS LAW FIRM, Attorneys for Plaintiff, JANEY CICCOLELLA, and JERRY BUSBY, ESQ. of the law firm COOPER LEVENSON, P.A., Attorneys for Defendant, SMITH'S FOOD & DRUG CENTERS, INC. that certain discovery deadlines in this matter be continued for a period of 90 days to all the parties additional time to complete discovery without having to burden the Court with another stipulation to extend in the future.

         DISCOVERY COMPLETED TO DATE

1. On September 10, 2018, the parties conducted the Rule 26 Conference;
2. On September 20, 2018, the parties submitted a Stipulated Discovery Plan and Scheduling Order for the Court's approval;
3. On September 24, 2018, Defendant served written discovery to Plaintiff;
4. On November 1, 2018, Plaintiff served written responses to ...

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