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Leany v. Zurich American Insurance Co.

United States District Court, D. Nevada

February 14, 2017

TODD L. LEANY, Plaintiff,
v.
ZURICH AMERICAN INSURANCE COMPANY, a New York corporation; Defendants. ZURICH AMERICAN INSURANCE COMPANY, Counterclaimant,
v.
TODD L. LEANY, Counterdefendant.

          ALBRIGHT, STODDARD, WARNICK & ALBRIGHT D. CHRIS ALBRIGHT, Esq. WILLIAM H. STODDARD, JR., Esq. Attorneys for Plaintiff/Counterdefendant.

          BALLARD SPAHR LLP ABRAN E. VIGIL, ESQ., MARIA A. GALL, ESQ., JOSEPH P. SAKAI, ESQ., Attorneys for Defendant/Counterclaimant.

          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.

         COMES 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.

         GALL, 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”).

         More 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, 2017;
• That the current discovery cut-off date of April 17, 2017 be extended an additional sixty (60) days to June 16, 2017;
• 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.

         This 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 discussed below.

         GOOD CAUSE ANALYSIS and LR II 26-4 STATEMENTS

         LR 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.

         LR II 26-4(b) Statement: Written discovery has not yet been completed. No ...


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