United States District Court, D. Nevada
TODD L. LEANY, Plaintiff,
ZURICH AMERICAN INSURANCE COMPANY, a New York corporation; Defendants. ZURICH AMERICAN INSURANCE COMPANY, Counterclaimant,
TODD L. LEANY, Counterdefendant.
ALBRIGHT, STODDARD, WARNICK & ALBRIGHT D. CHRIS ALBRIGHT,
Esq. WILLIAM H. STODDARD, JR., Esq. Attorneys for
BALLARD SPAHR LLP ABRAN E. VIGIL, ESQ., MARIA A. GALL, ESQ.,
JOSEPH P. SAKAI, ESQ., Attorneys for
PLAINTIFF'S JOINT MOTION TO MODIFY THE DISCOVERY
PLAN AND SCHEDULING ORDER AND TO EXTEND THE DISCOVERY
DEADLINE AND OTHER DEADLINES SET FORTH THEREIN
Honorable Richard F. Boulware, II Magistrate Judge.
NOW, Plaintiff/Counterdefendant, TODD L. LEANY,
individually (hereinafter sometimes “Leany” or
“Plaintiff”), by and through his counsel of
record, D. CHRIS ALBRIGHT, ESQ. and WILLIAM H. STODDARD, JR.
of the law firm of ALBRIGHT, STODDARD, WARNICK &
ALBRIGHT; and Defendant/Counterclaimant, ZURICH AMERICAN
INSURANCE COMPANY (hereinafter sometimes “Zurich”
or “Defendant”), by and through its counsel of
record ABRAN E. VIGIL, ESQ., MARIA A.
ESQ., and JOSEPH P. SAKAI, ESQ. of BALLARD SPAHR LLP, and,
pursuant to LR IA 6-1 and LR II
26-4, said parties hereby jointly move this Court
for an Order to Modify the Order (ECF No. 12) which set forth
this Court's Discovery Plan and Scheduling Order
(hereinafter the “Prior Scheduling Order”).
specifically, the parties hereby jointly move for a sixty
(60) day extension of all dates set forth in the Prior
Scheduling Order (ECF No. 12) which have not already expired.
In other words, the parties request that:
• The February 17, 2017 deadline for expert disclosures
and reports be extended an additional 60 days, until April
18, 2017, with rebuttal expert reports being due on May 17,
• That the current discovery cut-off date of April 17,
2017 be extended an additional sixty (60) days to June 16,
• That the current deadline for filing dispositive
motions of May 17, 2017, be extended an additional sixty (60)
days to July 17, 2017; and
• That the current deadline for filing the Joint
Pre-Trial Order of June 17, 2017, be extended an additional
sixty (60) days to August 16, 2017.
Motion is filed for good cause shown as set forth in the
below ANALYSIS Section hereof, and is filed in a timely
manner pursuant to LR II 26-4, 21 days before the expiration
of any deadline sought to be extended herein, with the
exception of the deadline for expert disclosures and reports,
which the parties seek to extend for good cause shown, as
CAUSE ANALYSIS and LR II 26-4 STATEMENTS
II 26-4(a) Statement: Discovery completed in this matter
to Dated: The parties have made their initial disclosures
pursuant to FRCP 26. Plaintiff has served its first set of
Interrogatories, Requests to Produce and Requests for Admit.
Defendant Zurich is in the process of preparing written
discovery, which will also be served in the near future.
II 26-4(b) Statement: Written discovery has not yet been
completed. No ...