United States District Court, D. Nevada
T. KENNEDY, ESQ. ATTORNEY FOR PLAINTIFF
COLE AICKLEN SHARON A. PARKER, ESQ. ATTORNEY FOR DEFENDANT
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
AND RELATED DATES (SECOND REQUEST)
Plaintiff, GRACE PETASHNICK, by and through her undersigned
counsel, KIRK T. KENNEDY, ESQ., and the Defendant LOWE'S
HOME CENTERS, LLC by and through its undersigned counsel,
JOSH COLE AICKLEN, ESQ. and SHARON A. PARKER, ESQ., of the
firm of Lewis Brisbois et al., submit this second request to
extend all fo the discovery deadline dates in this matter.
The current discovery deadline is January 14, 2020.
a negligence action based on diversity jurisdiction.
Defendant denies all claims for relief.
Discovery Completed to Dated:
parties have exchanged all Rule 26 lists of witnesses and
initial document production. The Defendant served written
discovery requests upon the Plaintiff. The Plaintiff has
answered those discovery requests. The parties have served
supplemental document disclosures on both sides.
Defendant previously noticed the Plaintiff's deposition
for July 23, 2019, however it was vacated due to ongoing
medical concerns with the Plaintiff's condition.
Discovery that remains to be completed: Plaintiff intends to
take 1-2 deposition of the persons most knowledgeable from
the Defendant. The Defendant needs to take the
Plaintiff's deposition once her health condition
stabilizes such that she can be deposed. The Defendant may
also take the depositions of the Plaintiff's treating
providers not in excess of 10.
parties may also take the depositions of any experts
disclosed by either side. The Defendant may also set an
independent medical evaluation of the Plaintiff.
Reasons why discovery has not been completed to Dated:
the first discovery extension filed on July 26, 2019, the
parties have not been able to schedule the Plaintiff's
deposition due to ongoing health related issues. However, the
Plaintiff is now in a position to be subjected to the
deposition process by the Defendant. The completion of the
Plaintiff's deposition will then dictate the nature and
extent of the remaining discovery required by the parties.
Estimated time required for remaining discovery: The parties
request a discovery extension of 90 days from January 14,