Opinion
2:21-cv-00116-KJD-EJY
01-18-2022
LINDA SEVERSON, Plaintiff, v. SMITH'S FOOD & DRUG CENTERS, INC., a Foreign Corporation, d/b/a SMITHS; DON ENGLAND, an Individual; DAVID HUFFER, an Individual DOE EMPLOYEE; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.
8MARCUS A. BERG, ESQ. Nevada Bar No. 9760, JOHN C. FUNK, ESQ. Nevada Bar No. 9255 jOSS BERG INJURY LAWYERS Attorneys for Plaintiff MARCUS A. BERG, ESQ. Nevada Bar No. 9760 Attorneys for Plaintiff Linda Severson JERRY S. BUSBY Nevada Bar #001107 GREGORY A. KRAEMER Nevada Bar #010911 Attorneys for Defendant Smith's Food and Drug
8MARCUS A. BERG, ESQ. Nevada Bar No. 9760, JOHN C. FUNK, ESQ. Nevada Bar No. 9255 jOSS BERG INJURY LAWYERS Attorneys for Plaintiff
MARCUS A. BERG, ESQ. Nevada Bar No. 9760 Attorneys for Plaintiff Linda Severson
JERRY S. BUSBY Nevada Bar #001107 GREGORY A. KRAEMER Nevada Bar #010911 Attorneys for Defendant Smith's Food and Drug
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)
Plaintiff LINDA SEVERSON (hereinafter “Plaintiff”) and Defendant SMITH'S FOOD & DRUG CENTERS, INC., (hereinafter “Defendant”) (collectively “Parties”), by and through their respective counsel of record, do hereby stipulate to extend the remaining deadlines in the current scheduling order and discovery plan in this matter for a period of sixty (60) days for the reasons explained herein, under LR 26-3 and LR IA 6-1, averring that this is the second such discovery extension requested in this matter.
DISCOVERY COMPLETED TO DATE
1. The Parties held a FRCP 26(f) Conference on February 24, 2021;
2. Plaintiff served her Initial FRCP 26(a) Disclosure of Witnesses and Documents on April 11, 2021;
3. Defendant served its Initial FRCP 26(a) Disclosure of Witnesses and Documents on May 5, 2021;
4. Defendant served Plaintiff with Interrogatories, Requests for Production of Document and Requests for Admissions on May 19, 2021 5. Plaintiff served her First Supplement to FRCP 26(a) Disclosure of Witnesses and Document on June 8, 2021;
6. Plaintiff answered Defendant's discovery requests on June 15, 2021;
7. Plaintiff served Defendant with Interrogatories and Requests for Production of documents on August 3, 2021;
8. Defendant answered Plaintiff's discovery requests on September 8, 2021;
9. Plaintiff's deposition was taken on September 16, 2021;
10. A site inspection with the Experts was done on November 5, 2021;
11. Plaintiff served her Expert Disclosures on November 16, 2021;
12. Defendant served its Expert Disclosures on December 27, 2021;
13. Plaintiff has executed several authorizations for medical records;
DISCOVERY TO BE COMPLETED AND REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED
Plaintiff and Defendant anticipate that further depositions of pertinent witnesses will be necessary, including Plaintiff's deposition of Defendant's FRCP 30(b)(6) designee(s). Due to the new variant of COVID-19 and the holiday schedule it's been difficult to coordinate these remaining depositions. The parties are currently working on securing dates for these remaining depositions.
CURRENT DATES AND PROPOSED SCHEDULE
CURRENT DATE
1. Discovery Cut-off: January 21, 2022;
2. Dispositive Motions: February 21, 2022 3. Pre-Trial Order: March 23, 2022
PROPOSED NEW DATE
1. Discovery Cut-off March 21, 2022
2. Dispositive Motions April 21, 2022
3. Pre-Trial Order May 23, 2022 or or 30 days after resolution of dispositive motions per Local Rule 26-1(e)(5).
If this extension is granted, all remaining discovery mentioned above should be concluded within the stipulated extended deadline. The parties aver that this request for extension of discovery deadlines is made by the parties in good faith and not for the purpose of delay.
IT IS SO ORDERED.