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Lambert v. Property and Casualty Insurance Co. of Hartford

United States District Court, D. Nevada

November 29, 2017

MARY JEAN LAMBERT, Plaintiff,
v.
PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD; HARTFORD UNDERWRITERS INSURANCE COMPANY, companies and entities licensed to do business in Arizona and Nevada; DOES 1 through 10; XYZ Corporations 11 through 20; and ABC Limited Liability Companies 21 through 30, inclusive, Defendants.

          DARREN T. BRENNER, ESQ., WILLIAM S. HABDAS, ESQ., Akerman LLP., Attorneys for Property and Casualty Insurance Company of Hartford.

          BERNSTEIN & POISSON, SCOTT L. POISSON, ESQ., CHRISTOPHER D. BURK, ES, Attorneys for Mary Jean Lambert.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Defendant 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.

         I. Introduction.

         This 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 Docket #12].

         II. Discovery Status.

         On 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 ...

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