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Conway v. National General Insurance Co.

United States District Court, D. Nevada

June 26, 2016

ROBERT CONWAY, Plaintiff,
v.
NATIONAL GENERAL INSURANCE COMPANY, duly authorized to conduct business in the State of Nevada; DOES I through X, and ROE CORPORATIONS I through X, inclusive, Defendant.

          THOMAS E. WINNER, MATTHEW J. DOUGLAS, ATKIN WINNER & SHERROD, Attorneys for Defendant NGIC.

          Ryan M. Anderson, Esq., Kimball Jones, Esq., Attorneys for Plaintiff Conway.

          STIPULATION AND ORDER TO EXTEND DEFENDANT'S TIME TO RESPOND TO WRITTEN DISCOVERY AND PLAINTIFF'S DEADLINE TO FILE AN OPPOSITION TO DEFENDANT'S MOTION FOR PROTECTIVE ORDER (DOC #18) (FIRST REQUEST)

          GEORGE W. FOLEY United States Magistrate Judge.

         Pursuant to LR 7-1, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend the time for Defendant to respond to Plaintiffs written discovery by fourteen (14) days and extend Plaintiffs time to Oppose Defendants Motion for a Protective Order (Doc. #18, herein) by fourteen days in the above-captioned case The parties do not believe this will affect the dates as set forth in the current Stipulated Amended Discovery Plan and Scheduling Order. In support of this Stipulation and Request, the parties state as follows:

1. On January 31, 2017 Plaintiff filed his Complaint in the eight Judicial District Court of Clark County, NV.
2. Plaintiff served Defendant with Complaint February 15, 2017;
3. Defendant filed its Petition for Removal and Answer on March 15, 2017;
4. March 30, 2017 Plaintiff filed its Motion to Remand to State Court which Defendant opposed;
5. On April 26, 2017 the Court denied Plaintiffs Motion to Remand;
6. On April 28, 2017 the parties held their Initial FRCP 26 Conference and submitted a proposed Discovery Scheduling Order;
7. The proposed Discovery Plan was approved by the Court on May 1, 2017;
8. On May 25, 2017 Plaintiff served written interrogatories and Requests for Production on Defendant;
9. On June 13, 2017 the parties filed a Stipulation to extend the discovery deadlines which was granted by the Court on June 15, 2017;
10. On June 20, 2017 Defendant filed its Motion for Protective Order regarding Depositions of Defendant ...

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