Filed: Nov. 13, 2018
Latest Update: Nov. 13, 2018
Summary: STIPULATION AND ORDER FOR LEAVE TO COMPLETE THE DEPOSITION OF JASWINDER GROVER, MD OUTSIDE THE DISCOVERY PERIOD CAM FERENBACH , Magistrate Judge . Plaintiff SYLVIA LEYS (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record, do hereby stipulate to conduct certain discovery outside the discovery period. Specifically, the parties stipulate that The deposition of Jaswinder Grover M.D., which commenced on May
Summary: STIPULATION AND ORDER FOR LEAVE TO COMPLETE THE DEPOSITION OF JASWINDER GROVER, MD OUTSIDE THE DISCOVERY PERIOD CAM FERENBACH , Magistrate Judge . Plaintiff SYLVIA LEYS (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record, do hereby stipulate to conduct certain discovery outside the discovery period. Specifically, the parties stipulate that The deposition of Jaswinder Grover M.D., which commenced on May 2..
More
STIPULATION AND ORDER FOR LEAVE TO COMPLETE THE DEPOSITION OF JASWINDER GROVER, MD OUTSIDE THE DISCOVERY PERIOD
CAM FERENBACH, Magistrate Judge.
Plaintiff SYLVIA LEYS (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant"), by and through their respective counsel of record, do hereby stipulate to conduct certain discovery outside the discovery period. Specifically, the parties stipulate that The deposition of Jaswinder Grover M.D., which commenced on May 25, 2018, shall be completed on January 11, 2019, or the first available date thereafter.
DISCOVERY COMPLETED TO DATE
• The parties have conducted an FRCP 26(f) conference.
• The parties have served and exchanged their respective FRCP 26(a) initial disclosures and supplements thereto.
• Plaintiff has served written discovery requests to Defendant, and Defendant timely served its responses and objections to the same.
• Defendant has served written discovery requests to Plaintiff, and Plaintiff timely served her responses and objections to the same.
• Each party has made their respective expert disclosures.
• Plaintiff has taken depositions of fact witnesses, including Walmart employees Marlen Hughes, Drake Jenkins, and Dennis Dellere.
• Defendant has taken the deposition of Plaintiff's expert John Peterson.
• Defendant has taken deposition of Plaintiff's treating provider Dr. Moratillo.
• Defendant has deposed Plaintiff's treating provider Dr. Grover for approximately 1.5 hours
• Defendant has obtained executed authorizations from Plaintiff and has subpoenaed and records from Plaintiff's providers and continues to subpoena updated records on an ongoing basis.
• Defendant has noticed the deposition of Plaintiff, which will be completed on November 13, 2018 pursuant to a stipulation of the parties (ECF No. 44).
DISCOVERY TO BE COMPLETED OUTSIDE THE DISCOVERY PERIOD
Discovery to be completed includes:
• Completion of the deposition of Plaintiff's treating provider, Dr. Grover.
The parties aver that good cause exists for the request pursuant to Local Rule 6-1. Dr. Grover's deposition was noticed by Walmart's former counsel, Law Offices of Charles Abbott, PC, and commenced on May 25, 2018. Given the breadth of testimony to be obtained, former counsel noted on the record upon expiration of the allotted time, that the deposition remained open and would be completed at a later date. Discovery in this matter currently closes on November 12, 2018, however, Dr. Grover's first available date for completion of his deposition is January 11, 2019. As such, the parties have cordially agreed to that Dr. Grover's Deposition may be completed outside the discovery period on January 11, 2019, or the first available date thereafter should Dr. Grover's availability change prior to this date.
The parties aver that this request is made by the parties in good faith and not for the purpose of delay.
IT IS SO ORDERED.
