United States District Court, D. Nevada
T. BRENNER, ESQ., WILLIAM S. HABDAS, ESQ., Akerman LLP.,
Attorneys for Property and Casualty Insurance Company of
BERNSTEIN & POISSON, SCOTT L. POISSON, ESQ., CHRISTOPHER
D. BURK, ES, Attorneys for Mary Jean Lambert.
STIPULATION AND ORDER TO EXTEND DISCOVERY
Property and Casualty Insurance Company of Hartford
(Defendant), incorrectly named as Hartford
Underwriters Insurance Company, and plaintiff Mary Jean
Lambert (Plaintiff), respectfully submit the
following stipulation requesting a sixty (60) day extension
of the current scheduling order deadlines.
case is a dispute arising out of an automobile insurance
policy. Plaintiff allegedly suffered injuries as a result of
a motor vehicle collision on April 11, 2012, and made a claim
on her insurance policy. Plaintiff filed a complaint in State
Court on April 17, 2017, alleging breach of contract,
contractual breach of implied covenant and good faith and
fair dealing, and unfair claims practices. On May 26, 2017,
Defendant removed this matter to Federal Court. A discovery
plan and scheduling order was entered on August 24, 2017 [ECF
August 24, 2017, the court entered a discovery plan and
scheduling order which set the following deadlines:
(a). Discovery Cut Off: Wednesday, January 31, 2018.
(b). Motions to amend pleadings or add parties: Thursday,
November 2, 2017.
(c). Initial Expert Disclosures: Monday, December 4, 2017.
(d). Rebuttal Expert Disclosures: Wednesday, January 3, 2018.
(e). Interim Status Report: Monday, December 4, 2017.
(f). Dispositive Motions: Friday, March ...