Mackenzie v. IKEA US Retail, LLC, No. 2:2021cv02097 - Document 25 (D. Nev. 2022)
Court Description: ORDER Granting 24 Joint Pretrial Order. Calendar Call set for 1/18/2023 at 01:00 PM in LV Courtroom 6A before Judge James C. Mahan. Jury Trial set for 1/23/2023 at 09:00 AM in LV Courtroom 6A before Judge James C. Mahan. Signed by Judge James C. Mahan on 12/28/2022. (Copies have been distributed pursuant to the NEF - LOE)
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Mackenzie v. IKEA US Retail, LLC Doc. 25 Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 1 of 30 1 2 3 4 5 6 7 8 MICHAEL C. KANE. ESQ. Nevada Bar No.: 10096 BRADLEY J. MYERS, ESQ. Nevada Bar No.: 8857 ZACHARY W. LIVINGSTON, ESQ. Nevada Bar No.: 15954 THE702FIRM INJURY ATTORNEYS 400 S. 7th Street, 4th Floor Las Vegas, Nevada 89101 Telephone: (702) 776-3333 Facsimile: (702) 505-9787 Email: service@the702firm.com Attorneys for Plaintiff UNITED STATES DISTRICT COURT 9 10 DISTRICT OF NEVADA MICHAEL MACKENZIE, Case No. : 2:21-cv-2097-JCM-NJK 11 12 13 14 15 Plaintiff, JOINT PRE-TRIAL ORDER vs. IKEA US RETAIL, LLC., fka IKEA U.S. WEST, INC.; DOE EMPLOYEE I; DOES I through X, inclusive and ROE CORPORATIONS I through X, inclusive. 16 Defendants. 17 18 After pretrial proceedings in this case, 19 IT IS ORDERED: 20 21 I. INTRODUCTION 1. This is a premise case resulting from an incident that occurred on or about June 21, 2019. 22 Plaintiff, MICHAEL MACKENZIE was at Defendant IKEA’s premises, as an invitee of 23 24 Defendants, where he was shopping and proceeded to load a Kivik box 2. While retrieving the 25 Kivik box 2, he alleges that an unsecured Kivik Box 1 fell, striking Plaintiff in the head. Plaintiff 26 alleges the Kivik Box 1 was not properly secured and caused serious injuries to Plaintiff. 27 2. 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 Defendant denies the claims of 1) negligence. Defendant has offered additional affirmative defenses as part of its pleadings in this action, and Defendant reserves the right to rely on the 1 Dockets.Justia.com Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 2 of 30 1 pleadings on file in this action to articulate its contentions in this case. II. STATEMENT OF JURISDICTION: 2 3 This action was originated by the filing of a Complaint in the District Court, Clark County, 4 Nevada on April 27, 2021. Defendants Answered the Complaint on September 1, 2021 and 5 6 removed the case from State Court to Federal Court on November 23, 2021, citing diversity between the parties and that this Court has jurisdiction of the matter under 28 U.S.C. § 1332, 1441 7 8 9 10 and 1446. III. THE FOLOWING FACTS ARE ADMITTED BY THE PARITES AND REQUIRE NO PROOF: None. 11 12 13 14 IV. THE FOLLOWING FACTS, THOUGH NOT ADMITTED, WILLNOT BE CONTESTED AT TRIAL BY EVIDENCE TO THE CONTRARY: None. 15 16 17 V. THE FOLLOWING ARE ISSUES OF FACT TO BE TRIED AND DETERMINED AT TRIAL: The following facts are admitted by the parties and require no proof: None at this time. The 18 following are issues of fact to be tried and determined at trial: 19 20 21 PLAINTIFF: 1. stacked in an unsafe and unsecure manner; 22 23 2. 24 25 Whether Defendant knew or should have known that the subject boxes were Whether Defendant failed to properly warn Plaintiff of the danger of the subject boxes; 3. Whether Plaintiff sustained Injuries as a result of the subject incident; and 4. Defendant’s choice of using a self-serve mode of operation. 26 27 28 DEFENDANT: THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 2 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 3 of 30 1 1. of this litigation. 2 3 2. 4 5 6 7 Whether Defendant was negligent in the operation of conducting business at the time of the incident which forms the basis of this litigation VI. THE FOLLOWING ARE ISSUES OF LAW TO BE TRIED AND DETERMINED AT TRIAL: 1. 8 Whether Defendant breached its duty of care owed to Plaintiff as an invitee or patron of its establishment by failing to stack merchandise properly and securely in in 9 10 Whether Defendant was negligent at the time of the incident which forms the basis the self-serve furniture warehouse of its premises; 2. Whether Defendant failed to adequately hire, train, and supervise its employees in 11 safely stacking and securing merchandise in the self-serve furniture warehouse of its 12 premises; 13 14 3. Defendant’s choice of using a self-serve mode of operation; 15 4. Whether Defendant’s breach caused any damages to Plaintiff; and 16 5. The nature, extent and value of Plaintiff’s accident-related damages, including 17 without limitation, the expenses of past medical treatment, past lost wages, past pain 18 and suffering, and future pain and suffering. 19 20 21 6. The issues of law raised in the parties’ anticipated Motions in Limine. 7. Whether Defendant was negligent at the time of the incident which forms the basis of this litigation. 22 23 8. 24 Whether Defendant failed to adequately hire, train, and supervise its employees in safely stacking and securing merchandise in the self-serve furniture warehouse of its 25 premises; 26 9. Whether such negligence, if any, was a proximate cause of Plaintiff’s alleged 27 28 injuries and alleged damages. THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 3 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 4 of 30 1 10. forms the basis of this litigation. 2 3 11. 4 5 Whether Plaintiff was comparatively negligent at the time of the incident which Whether the comparative negligence of Plaintiff, if any, was a proximate cause of Plaintiff’s alleged injuries and alleged damages. 12. 6 Whether the comparative negligence of Plaintiff, if any, is greater than the negligence of the Defendant, if any. 7 8 13. Whether any risks and dangers involved in the factual situation set forth in the Complaint, if any, were open and obvious to Plaintiff. 9 10 14. Whether Plaintiff was involved in a prior accident or other form of traumatic event. 11 15. Whether any prior accident or other form of traumatic event involving Plaintiff, if 12 13 any, caused the injuries of which he complains in this litigation. 16. Whether the occurrence which is the subject matter of this action was avoidable. 17. Whether the occurrence which is the subject matter of this action was caused in 14 15 whole or in part by the actions of a third party, outside of the control of any party 16 to this litigation. 17 18 18. Whether the occurrence which is the subject matter of this action was caused in 19 whole or in part by the negligence of a third party, outside of the control of any 20 party to this litigation. 21 19. The percentage of reduction for the amount of damages that is commensurate 22 with the comparative negligence, in any, of Plaintiff. 23 24 20. basis of this litigation. 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 Whether Plaintiff suffered injuries resulting from the incident which forms the 21. Whether Plaintiff suffered monetary damages in the form of past medical expenses stemming from alleged injuries resulting from the incident which forms the basis of this litigation. 4 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 5 of 30 1 22. Plaintiff suffered from alleged injuries as a proximate result of this accident. 2 3 23. 4 Whether Plaintiff will continue to suffer monetary damages in the future in the form of medical expenses stemming from alleged injuries resulting from the 5 6 The amount of monetary damages in the form of past medical expenses, if any, incident which forms the basis of this litigation. 24. The amount of monetary damages in the form of future medical expenses, if 7 any, Plaintiff will suffer from alleged injuries as a proximate result of this 8 accident. 9 10 25. 11 12 Whether Plaintiff suffered injuries to his body, including, but not limited to his, spine resulting from the incident which forms the basis of this litigation. 26. 13 Whether Plaintiff suffered monetary damages in the form of past medical expenses stemming from alleged injuries resulting from the incident which 14 forms the basis of this litigation. 15 27. The amount of monetary damages in the form of past medical expenses, if 16 any, Plaintiff suffered from alleged injuries as a proximate result of this 17 accident. 18 19 28. form of medical expenses stemming from injuries allegedly resulting from the 20 incident which forms the basis of this litigation. 21 22 Whether Plaintiff will continue to suffer monetary damages in the future in the 29. The amount of monetary damages in the form of future medical expenses, if any, Plaintiff will suffer from injuries as a proximate result of this accident. 23 24 30. Whether Plaintiff failed to mitigate his damages. 25 31. Whether Plaintiff suffered from any pre-existing injuries and problems in his 26 27 28 body at the time of the incident which forms the basis of this litigation. 32. Whether Plaintiff’s medical costs for treatment derived from unreasonable or unnecessary treatment. THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 5 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 6 of 30 1 33. 2 Whether Plaintiff’s medical costs for treatment were usual and customary in the Las Vegas community. 3 34. 4 Whether Plaintiff’s medical costs for treatment to his head were presented solely to improperly attempt to increase the value of this case. 5 35. Whether Plaintiff’s alleged injuries were the result of a superseding intervening 36. cause. Whether Plaintiff suffered from any pre-existing injuries and problems at the time 6 7 8 of the incident which forms the basis of this litigation. 9 37. 10 Such evidentiary and procedural issues which may arise during the trial of this action. 11 38. 12 Any remaining issues which may be brought before the Court after rulings on Motions in Limine. 13 VII. 14 EXHIBITS 15 The undersigned parties are continuing to refine their joint exhibit list to avoid duplication 16 and to stipulate as feasible. The parties currently reserve any objections as to foundation and 17 admissibility. 18 (a) 19 20 The following exhibits are stipulated into evidence in this case and may be so marked by the clerk: NONE. (b) As to the following exhibits, the party against whom the same will be offered objects to their admission on the grounds stated: 21 22 The following exhibits, though not agreed as admissible evidence in this case, are subject 23 24 to be used by the parties. 25 /// 26 /// 27 /// 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 6 Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 7 of 30 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 8 of 30 1 4. QHR Pharmacy billing statement. 5. Innovative Pain Care Center medical records and billing statement. 6. Las Vegas Radiology, FILMS, medical records and billing statement. 7. Kelly Hawkins medical records and billing statement. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 8 inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 9 of 30 1 2 3 4 5 8. Sahara Surgery Center medical records and billing statement. 9. Western Regional Center for Brain and Spine Surgery records and billing statement. 10. Las Vegas Neurosurgical Institute medical records and billing statement. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 9 for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 10 of 30 1 2 11. 3 4 5 6 7 8 9 10 12. 11 12 13 14 15 16 17 18 13. 19 20 21 22 23 24 25 26 27 28 14. are excluded by any motion in limine. Pueblo Medical Imaging FILMS, medical records inadmissible, lack foundation, and billing statement. is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Desert Radiology FILMS, medical and billing inadmissible, lack foundation, records. is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the and/or Federal statutory Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Ikea Incident Report inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Eight (8) Colored Photographs of the Incident Scene inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 10 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 11 of 30 1 2 3 4 5 6 15. 7 8 9 10 11 12 13 14 16. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17. of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Four (4) Colored Photographs of Plaintiff’s Suction inadmissible, lack foundation, Treatment is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Three (3) Colored Photographs of the Opposite inadmissible, lack foundation, Aisle of the Incident Scene is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. IKEA Training Materials inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 11 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 12 of 30 1 2 3 18. 4 5 6 7 8 9 10 11 19. 12 13 14 15 16 17 18 19 20. 20 21 22 23 24 25 26 27 28 21. Defendants further object to the extent that this/these documents are excluded by any motion in limine. IKEA Warehouse Manual inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. IKEA Timecard Audit Trail inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. IKEA Service Agreement Summary for inadmissible, lack foundation, Housekeeping & Additional Services – US is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Self-Serve Warehouse and Markethall Assessments inadmissible, lack foundation, is/are not genuine or authentic; THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 12 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 13 of 30 1 2 3 4 5 6 7 8 22. 9 10 11 12 13 14 15 16 23. 17 18 19 20 21 22 23 24 25 26 27 28 24. constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Self-Serve and Full-Service Warehouse Layout inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. U.S. Retail Store Risk & Compliance Operations inadmissible, lack foundation, Manual is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Standard Operating Procedures for Supply Chain inadmissible, lack foundation, Security is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 13 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 14 of 30 1 2 3 4 25. 5 6 7 8 9 10 11 12 26. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 27. Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Safety & Security Manual – Retail inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Five (5) Photographs of the Subject Boxes Taken on inadmissible, lack foundation, June 27, 2019 is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. Plaintiff’s Complaint inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 14 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 15 of 30 1 28. Defendant’s Answer to Plaintiff’s Complaint 29. National Safety Council (2000). Accident Prevention Manual for Business and Industry, 14th Edition 30. Expert Impeachment File for Jeffrey Wang, M.D. 31. Computation of Damages 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 15 inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; violative of the best evidence rule, are not relevant, and are inadmissible Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 16 of 30 for any other reason set forth within the statutory and/or Federal Rules of Evidence in Nevada, or any other Nevada law. Defendants further object to the extent that this/these documents are excluded by any motion in limine. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 32. Curriculum Vitae, Fee Schedule and Testimony List for Gary White 33. Gary White’s Initial Expert Report dated March 2022 34. Gary Whites First Supplemental Expert Report dated May 7, 2022 35. Gary Whites Second Supplemental Expert Report dated July 19, 2022 36. Curriculum Vitae, Fee Schedule and Testimony List for Eric Brimhall, MD. 37. Curriculum Vitae, Fee Schedule and Testimony List for Suart Kaplan MD. 38. Curriculum Vitae, Fee Schedule and Testimony List for Jason Garber, MD 39. Deposition Transcript of Austin Bickel Plaintiff’s Use of Demonstrative Exhibits: Plaintiff may offer, at trial, certain Exhibits for demonstrative purposes including, but not limited to the following: 1. Demonstrative and charts relating to Plaintiff’s damage claims; 18 2. Story board and computer digitized power point images; 19 20 21 3. Blow-ups/transparencies/digitized images of various records; and 4. Plaintiff reserves the right to offer into evidence any exhibit timely and properly disclosed 22 during discovery for the purpose of demonstration at trial. Additionally, Plaintiff reserves the right to 23 offer into evidence any exhibit offered by any other parties to this action. 24 Plaintiff’s will offer the following depositions: 25 Deponent Austin Bickel FRCP 30(b)(6) Designee of Defendant IKEA 26 27 Deposition Date April 22, 2022 June 7, 2022 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 16 Pages & Lines N/A N/A Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 17 of 30 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 18 of 30 1 2 3 11. 4 5 6 7 8 9 10 12. does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000016-IKEA000033 Las Vegas Radiology Billing Records Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000034-IKEA000072 Las Vegas Urology Medical Records 11 12 13 14 15 16 17 13. 18 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000073-IKEA000207 Legacy Urgent Care Billing and Medical Records 19 20 21 22 23 24 25 14. Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000208-IKEA000227 QHR Pharmacy Records 26 27 28 Defendant does not intend to introduce THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 18 inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; are not relevant, and are inadmissible for any other reason set forth within the statutory Federal Rules of Evidence, or any other Nevada law. Plaintiff further objects to the extent that this/these documents are excluded by any motions in limine. inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; are not relevant, and are inadmissible for any other reason set forth within the statutory Federal Rules of Evidence, or any other Nevada law. Plaintiff further objects to the extent that this/these documents are excluded by any motions in limine. Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 19 of 30 1 2 3 4 5 15. 6 Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000228-IKEA000400 Sahara Surgery Center Billing and Medical Records 7 8 9 10 11 12 13 16. 14 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000401-IKEA000549 Timothy Soder Physical Therapy Medical Records 15 16 17 18 19 20 21 22 23 17. Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment IKEA000550-IKEA000650 Western Regional Center for Brain & Spine Surgery Billing and Medical Records 24 25 26 27 28 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 19 inadmissible, lack foundation, is/are not genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; are not relevant, and are inadmissible for any other reason set forth within the statutory Federal Rules of Evidence, or any other Nevada law. Plaintiff further objects to the extent that this/these documents are excluded by any motions in limine. Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 20 of 30 1 2 18. for foundation, expert testimony, and impeachment Innovative Pain Care Center bate stamped MED000001-142 3 4 5 6 7 8 9 19. Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Kelly Hawkins Physical Therapy bate stamped MED0000143-205 10 11 12 13 14 15 16 20. 17 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Las Vegas Neurosurgical Institute bate stamped MED000206-223 18 19 20 21 22 23 24 21. Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Pueblo Medical Imaging bate stamped MED000224-261 25 26 27 28 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 20 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 21 of 30 1 2 3 22. 4 so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment QHR Pharmacy bate stamped MED000262-298 5 6 7 8 9 10 11 23. 12 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Timothy Soder Physical Therapy bate stamped MED000299-317 13 14 15 16 17 18 19 24. 20 Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Western Regional Center for Brain and Spine Surgery bate stamped MED000318-328 21 22 23 24 25 26 27 28 25. Defendant does not intend to introduce Plaintiff’s medical records at trial unless and until Plaintiff is able to meet the burden for admissibility; if Plaintiff does so, Defendant reserves the right to use any and all admissible medical records for foundation, expert testimony, and impeachment Demonstrative exhibits, including: THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 21 inadmissible, lack foundation, is/are not Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 22 of 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1. Power point images, blowups and transparencies of exhibits. 2. Models of various parts of the human body. 3. Diagrams, drawings, pictures, photos, film, video, DVDE and CD ROM of various parts of the human body, diagnostic tests and surgical procedures. 4. Exemplars, models, or pictures of the surgical hardware/implantation devices used or expected to be used in the care and treatment of Plaintiff. 5. Power point images, drawings, diagrams, animations, story boards of the incident, the location of the incident. 6. Power point images and blowups of deposition transcripts, discovery responses, and jury instructions. 7. Maps, diagrams or models of the scene of the incident that is the subject of this litigation. genuine or authentic; constitute inadmissible hearsay; are unduly prejudicial; are not relevant, and are inadmissible for any other reason set forth within the statutory Federal Rules of Evidence, or any other Nevada law. Plaintiff further objects to the extent that this/these documents are excluded by any motions in limine. 16 17 18 19 20 Defendant’s will offer the following depositions: Deponent Michael Mackenzie Heather Vorce Eric Brimhall, MD Deposition Date June 2, 2022 June 22,2022 August 16, 2022 Pages & Lines N/A N/A N/A 21 22 Defendants incorporate any and all documents produced by Plaintiffs and all other parties 23 to this action, now and in the future by way of cross examination and/or rebuttal, subject to 24 objection. Defendants incorporate any and all documents or exhibits used by experts that they have 25 reviewed and relied upon to form their opinions. 26 Defendants reserve the right to object to any of Plaintiffs’ exhibits, to call any witnesses 27 28 named by Plaintiffs, to supplement their list of exhibits up and until the time of trial, including any THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 22 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 23 of 30 1 2 demonstrative exhibits. Defendants object to any witnesses or document identified by Plaintiffs which should be 3 excluded on the basis that they have not been produced, are not related or highly prejudicial or lack 4 foundation, or any other possible objections. 5 6 Defendant reserves the right to use any discovery responses and/or deposition testimony and/or deposition exhibits for impeachment and/or substantively as party admissions, as may be 7 8 9 10 relevant at trial. Defendant reserves the right to use demonstrative evidence. Defendant also reserves the right to use any exhibit listed or introduced by Plaintiff, or as previously produced by the parties. 11 The parties reserve any all-evidentiary objections for trial. The parties reserve the right to 12 object to the admissibility of trial exhibits on the basis of foundation, authenticity, hearsay, and 13 relevance. The parties further reserve the right to object to any exhibit being offered by each side 14 which has not been previously produced during the normal course of discovery proceedings, or 15 16 17 18 pursuant to stipulation and agreement of the parties. The parties also reserve any and all evidentiary objections for trial. In addition, neither inclusion of any documents within this disclosure made pursuant to 19 FRCP 26, nor acceptance of documents provided by any other party hereto in a disclosure made 20 pursuant to FRCP 26, shall be deemed as a waiver by these Defendants of any evidentiary rights 21 they may have with respect to those documents, including, but not limited to, objections related to 22 authenticity, materiality, relevance, foundation, hearsay, or any other right as may be permitted 23 24 25 pursuant to the Federal Rules of Evidence. Electronic evidence: The parties intend to offer and present evidence in electronic format 26 to jurors for purposes of jury deliberations pursuant to Local Rule 16-3(b)(9) and will 27 contact the court administrator for instructions on how to prepare evidence in electronic 28 format and for any other requirements set by the court. THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 23 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 24 of 30 Depositions: Defendant does not intend at this time to offer page and line designations for 1 2 any deposition transcripts. In the event Defendant learns that a witness is unavailable to testify at 3 trial, Defendant will notify all parties and the Court of page and line designations of the 4 unavailable witness’s deposition transcript to offer at trial. Defendant reserves the right to use all 5 6 depositions which have been conducted in this action to refresh recollection and/or to impeach a witness, and otherwise use at trial in accordance with the applicable rules, i.e., Fed. R. Civ. P. 32; 7 8 Fed. R. Evid. 801(d). The following witnesses may be called by the parties at trial: 9 10 No.: 11 FACT & PERCIPIENT WITNESSES: 12 Plaintiff’s Witnesses: 1. MICHAEL MACKENZIE c/o THE702FIRM 400 South 7th Street, Suite 400 Las Vegas, NV 89101 (702) 776-3333 2. IKEA US RETAIL, LLC fka IKEA U.S. WEST, INC. c/o OLSON CANNON GORMLEY & STOBERSKI 9950 West Cheyenne Avenue Las Vegas, NV 89129 (702) 384-4012 3. Austin Bickel IKEA US RETAIL, LLC fka IKEA U.S. WEST, INC. c/o OLSON CANNON GORMLEY & STOBERSKI 9950 West Cheyenne Avenue Las Vegas, NV 89129 (702) 384-4012 4. Heather Vorce 3062 Scenic Rhyme Avenue Henderson, NV 89044 (702) 861-3715 5. Christine Jason 7426 Elderberry St. San Antonio, TX 78240 (253) 212-2324 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 24 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 25 of 30 1 2 PLAINTIFF’S MEDICAL PROVIDERS – REPRESENTATIVES AND/OR DESIGNEES 1. Michael F. Schlaack, M.D. and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Quest Diagnostics PO Box 30584 Tampa, FL 33630 866.697.8378 2. Dean Yarbro, M.D., and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Legacy Urgent Care 105 N. Pecos Rd, Ste 111 Henderson, NV 89074 702.263.4555 3. Karlo Arciaga PT, and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Timothy Soder Physical Therapy 2779 W Horizon Ridge Pkwy, Ste 10 Henderson, NV 89052 702.897.1222 4. Michael Stellmacher, M.D. and/or Michael Schlaack, M.D. and/or Eric Brimhall, M.D. and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records QHR Pharmacy 7512 Westcliff Drive Las Vegas, NV 891545 702.331.6388 5. Michael Scott, PA-C, and/or Treating Physicians and/or Treating Nurses and/or 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 25 Fed. R. Civ. P. 30(B)(6) Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 26 of 30 Person Most Knowledgeable and/or Custodian of Records Innovative Pain Care Center 9065 S. Pecos Rd, Ste 230 Henderson, NV 89074 702.684.7246 1 2 3 4 5 6. David T. Wang, D.O. and/or Bhuvana P. Kittusamy, M.D. and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Las Vegas Radiology 7500 Smoke Ranch Road Las Vegas, NV 89146 702.254.5004 7. Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Key Health Medical Solutions, Inc./Kelly Hawkins L-4034 Columbus, OH 43260 818.575.5300 8. Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Kelly Hawkins Physical Therapy 8975 S. Pecos Rd, Ste 7A Henderson, NV 890874 800.929.4776 9. Stuart S. Kaplan, M.D., and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Western Regional Center for Brain and Spine Surgery 3012 S Durango Drive Las Vegas, NV 89117 702.835.0088 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 /// 28 /// THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 26 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 27 of 30 1 10. Eric J. Brimhall, M.D., and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Sahara Surgery Center 2401 Paseo Del Prado Las Vegas, NV 89102 702.362.7874 11. Jason Garber, M.D., and/or Treating Physicians and/or Treating Nurses and/or Person Most Knowledgeable and/or Custodian of Records Las Vegas Neurosurgical Institute 3012 South Durango Las Vegas, NV 89117 702.835.0088 2 3 4 5 6 7 8 9 10 11 12 EXPERT WITNESS: 13 1. 14 15 16 No.: Gary White 10 Lake Como Court Rancho Mirage, CA 92270 949-697-1500 Defendant’s Witnesses: 17 18 19 20 21 22 23 24 25 26 27 1. Michael Mackenzie c/o The702Firm 400 South 7th Street, Suite 400 Las Vegas, NV 89101 (702) 776-3333 2. 30(b)(6) Representative(s) and/or Charlotte Mireles Ikea U.S. Retail, LLC fka Ikea U.S. West, Inc. c/o Olson Cannon Gormley & Stoberski 9950 West Cheyenne Avenue Las Vegas, Nevada 89129 (702) 384-4012 3. Austin Bickel c/o Olson Cannon Gormley & Stoberski 9950 West Cheyenne Avenue Las Vegas, Nevada 89129 (702) 384-4012 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 27 Case 2:21-cv-02097-JCM-NJK Document 25 24 Filed 12/28/22 11/02/22 Page 28 of 30 4. Jeffrey C. Wang, M.D. Chief, Orthopaedic Spine Service Co-Director USC Spine Center Professor of Orthopaedic Surgery and Neurosurgery USC Spine Center 1450 San Pablo St., Suite 5400 Los Angeles, CA 90033 Tel.: (323)442-5303 1 2 3 4 5 6 7 In the instance that this matter does not resolve at mediation currently scheduled to take 8 place on Thursday, November 3, 2022, the parties agree that the witness and exhibit list may be 9 amended as required before trial. 10 The parties reserve the right to use any witnesses listed by any other party to this litigation. 11 The parties further reserve the right to name and list any witnesses deemed necessary for 12 13 rebuttal and/or impeachment purposes. 14 VIII. TRIAL DATE 15 Counsel have met and herewith submit a list of (3) agreed-upon trial dates: 16 1. The week of January 9, 2023; 2. The week of January 16, 2023; or 3. The week of January 23, 2023 17 18 19 It is expressly understood by the undersigned that the Court will set a trial of this matter on 20 21 one of the agreed-upon dates if possible; if not, the trial will be set at the convenience of the 22 Court’s calendar. 23 24 25 /// 26 27 28 /// /// THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 28 Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 29 of 30 ESTIMATED LENGTH OF TRIAL 1 2 3 It is estimated that the trial will take a total of 3-5 days. THE702FIRM INJURY ATTORNEYS OLSON CANNON GORMLEY & STOBERSKI Isl Zach Livingston ------------ 11/2/2022 MICHAEL C. KANE. ESQ. Nevada Bar No.: 10096 BRADLEY J. MYERS, ESQ. Nevada Bar No.: 8857 ZACHARY W. LIVINGSTON, ESQ. Nevada Bar No.: 15954 400 S. 7th Street, 4th Floor Las Vegas, Nevada 89101 Telephone: (702) 776-3333 Facsimile: (702) 505-9787 E-Mail: service@tlte702{irm.com Attorneys for Plaintiff Isl Stephanie Zinna ------------ 11/2/2022 JAMES R. OLSON, ESQ. Nevada Bar No.: STEPHANIE ZINNA, ESQ. Nevada Bar No.: 9950 W Cheyenne Ave Las Vegas, NV 89129 Telephone: (702) Facsimile: (702) E-Mail: Attorneys for Defendants IKEA US RETAIL, LLC FKA IKEA U.S. WEST, INC. 4 5 6 7 8 9 10 11 12 13 ACTION BY THE COURT 14 15 16 17 18 19 20 21 22 23 24 25 This case is set for court/jury trial on the fixed/stacked calendar on January 23, 2023 at 9:00 a.m. The Calendar call will be held on January 18, 2023, at 1:00 p.m. This pretrial order has been approved by the parties to this action as evidenced by their signatures or the signatures of their attorneys hereon, and the order is hereby entered and will govern the trial of this case. This order may not be amended except by court order and based upon the parties' agreement or to prevent manifest injustice. DATED: December 28, 2022 . t. ;<.u,__l rmSTATES DISTRICT JUDGE 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7" Sn·eet #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 29 Case 2:21-cv-02097-JCM-NJK Document 25 Filed 12/28/22 Page 30 of 30 CERTIFICATE OF SERVICE 1 2 I hereby certify that on the 2 day of November, 2022, I caused service of a true and correct 3 copy of the foregoing JOINT PRE-TRIAL ORDER to be made through the CM/ECF system of 4 the United States District Court for the District of Nevada (or, if necessary, by U.S. Mail, first 5 6 7 8 9 class, postage pre-paid), upon the following: James R. Olson, Esq. Stephanie Zinna, Esq. OLSON CANNON GORMLEY & STOBERSKI 9950 W Cheyenne Ave Las Vegas, NV 89129 Attorneys for Defendants IKEA US RETAIL, LLC FKA IKEA U.S. WEST, INC. 10 11 12 CM/ECF: ____X_______ U.S. Mail: ___________ Facsimile: ___________ 702-383-0701 13 14 15 /s/ Gloria L. Pacheco _______________________________________ 16 An Employee of THE702FIRM 17 18 19 20 21 22 23 24 25 26 27 28 THE702FIRM ATTORNEYS AT LAW 400 S. 7th Street #400 LAS VEGAS, NEVADA 89101 PHONE: (702) 776-3333 30
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