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Mosley v. Mercury Casualty Co.

United States District Court, D. Nevada

February 22, 2017

JESSE MOSLEY, an individual, Plaintiff,
v.
MERCURY CASUALTY COMPANY, a California corporation, Defendant.

          LAW OFFICES OF STEVEN J. PARSONS JOSEPH N. MOTT Attorneys for Plaintiff JESSE MOSLEY

          RANALLI ZANIEL FOWLER & MORAN, LLC BENJAMIN J. CARMAN Attorney for Defendant MERCURY CASUALTY COMPANY

          PLAINTIFF AND DEFENDANT'S JOINT MOTION TO MODIFY THE DISCOVERY PLAN AND SCHEDULING ORDER AND TO EXTEND THE DISCOVERY DEADLINE AND OTHER DEADLINES SET FORTH THEREIN

         Plaintiff, JESSE MOSLEY an individual, by his attorneys, Steven J. Parsons and Joseph N. Mott of LAW OFFICES OF STEVEN J. PARSONS, and MERCURY CASUALTY COMPANY, a California corporation, by and through its attorney, BENJAMIN J. CARMAN OF RANALLI ZANIEL FOWLER & MORAN, LLC, and, pursuant to LR IA 6-1 and LR II 26-4, said Plaintiff and the Defendants (comprising all of the parties hereto), hereby jointly move this Court for an Order to Modify the most recent Order (Doc. #15), which set forth this Court's Discovery Plan and Scheduling Order (hereinafter the "Prior Scheduling Order"), in order to allow the parties an additional ninety (90) day extension beyond the current discovery deadline of May 18, 2017, until August 16, 2017, to complete discovery herein. Parties also hereby jointly move for an additional ninety (90) day extension with respect to all other dates set forth in the most recent Prior Scheduling Order (Doc. #15) beyond the deadlines set forth therein.

         This Motion is filed for good cause shown as set forth below. Certain of the requests herein are not made more than 21 days before the expiration of any deadline sought to be extended herein, as normally required by LR II 26-4 (namely the expert disclosures deadline), but any such late submission is made for good cause.

         A. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:

1. Defendant's Initial Disclosure, pursuant to FRCP 26(f);
2. Plaintiff's Initial Disclosures, pursuant to FRCP 26(f);
3. Defendant's First Set of Request for Admissions to Plaintiff;
4. Defendant's First Set of Interrogatories to Plaintiff;
5. Defendant's First Set of Requests for Production of Documents to Plaintiff;
6. Plaintiff's First Set of Request for Production of Documents to Defendant;
7. Plaintiff's First Set of Interrogatories to Defendant;
8. Plaintiff's Second Set of Interrogatories to ...

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