United States District Court, D. Nevada
OFFICES OF STEPHEN M. DIXON Stephen M. Dixon, Esq. Attorney
for Plaintiffs, Judith Anny Styles & Leigh Ann Styles
DENNETT WINSPEAR, LLP Ryan L. Dennett, Esq. Jennifer Insley
Micheri, Esq. Attorneys for Defendant, State Farm Mutual
Automobile Insurance Company.
STIPULATION FOR EXTENSION OF TIME TO COMPLETE
DISCOVERY (FIRST REQUEST)
NOW, the parties above named, by and through counsel, and
move the Honorable Magistrate Judge for an Order continuing
Discovery and submit the instant Stipulation in accordance
with LR 6-1 and LR 26-4. The parties have conferred and agree
that an extension of remaining discovery dates (those
remaining dates not expired prior to the stay imposed by the
Court) is both necessary and warranted following the
Plaintiffs' retention of new counsel after its former
counsel, George W. Carter, Esq. and co-counsel, David Lee
Phillips, Esq. withdrew and various discovery matters were
not completed by Plaintiffs due to the issues previously
addressed in open Court on November 2, 2016 and December 4,
previous requests or extensions for time in which to complete
discovery in this matter have been requested.
extension of time for discovery is necessary and good cause
exists for the extension pursuant to Local Rule 26-4.
Pursuant to that Rule, the parties submit the following:
DISCOVERY THAT HAS BEEN COMPLETED
for the respective parties participated in a discovery
planning conference pursuant to Fed.R.Civ.P. 26(f). Lists of
witnesses and document productions were thereafter exchanged
by and between the parties. A Proposed Discovery Plan was
filed on June 22, 2017 and Ordered by the Court on June 26,
discovery to the Plaintiffs has been served and answered,
Plaintiffs' depositions have been previously scheduled,
but those depositions were stayed by the Court Order.
Defendant has disclosed its expert.
DISCOVERY THAT REMAINS TO BE COMPLETED
parties will be conducting additional factual and expert
discovery, including the depositions of Plaintiffs and of the
parties affiliated with Defendant State Farm involved in the
handling of Plaintiff's claim. Plaintiffs and Defendant
have agreed that Plaintiffs may disclose their rebuttal
expert as the time to do so had not yet expired when the Stay
went into effect and Defendant shall have the right to
supplement its expert disclosure, if necessary.
REASONS DISCOVERY WILL NOT BE COMPLETED WITHIN THE TIME
LIMITS SET BY THE DISCOVERY PLAN
the withdrawal of Plaintiffs' former counsel and
retention of new counsel, it has become necessary to extend
the discovery for a period of six months.
PROPOSED SCHEDULE FOR COMPLETING REMAINING
parties hereby stipulate and request that discovery dates in
this matter ...