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Ruiz v. Stewart Title Guaranty Co.

United States District Court, D. Nevada

December 28, 2017

ROBERT NUNEZ RUIZ, an Individual; and TERESA LYNN RUIZ, an Individual, Plaintiffs,
v.
STEWART TITLE GUARANTY COMPANY, a Texas corporation; STEWART TITLE COMPANY, a Texas Corporation; DOE DEFENDANTS 1 through 10; and ROE ENTITIES 1 through 10. Defendants.

          GERRARD COX LARSEN Douglas D. Gerrard, Esq. John M. Langeveld, Esq. Attorneys for Defendant STEWART TITLE GUARANTY COMPANY.

          FRIZELL LAW FIRM, PLLC R. Duane Frizell, Esq. Attorneys for Plaintiffs ROBERT NUNEZ RUIZ, and TERESA LYNN RUIZ.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES [SECOND REQUEST]

         Pursuant to Local Rules IA 6-1 and 26-4, and all applicable authority, Plaintiffs ROBERT NUNEZ RUIZ and TERESA LYNN RUIZ (collectively, "RUIZ"), by and through their attorneys, Frizell Law Firm, PLLC, and Defendant STEWART TITLE GUARANTY COMPANY ("STGC"), by and through its attorneys, Gerrard Cox Larsen, hereby stipulate and agree, subject to approval by the Court, to amend the current discovery plan and scheduling order, as set forth in the Order Granting First Stipulation for Extension of Time, dated October 24, 2017 [ECF No. 14], as further set forth herein:

         I. STATEMENT PURSUANT TO LR 26-4:

         A. Discovery Completed To Date.

         (i). Initial Discovery:

         RUIZ served their Initial Disclosures on October 14, 2017.

         STGC served its Initial Disclosures on September 13, 2017.

         RUIZ served its First Set of Interrogatories, Requests for Production, and Requests for Admission to STGC on October 19, 2017.

         The Parties put a great deal of time an effort into their Initial and Supplemental Disclosures. The Parties have already identified about 10-pages' worth of potential witnesses, and collectively have produced over 900 pages' worth of documents.

         (ii). Discovery Completed After The Court's First, 90-day Discovery Extension.

         On October 24, 2017, this Court entered its Order Granting First Stipulation for Extension of Time, whereby the Court granted the Parties' stipulation to extend the discovery period by 90 days. [ECF No. 14]. Since that date, the Parties have been diligently engaged in discovery, and have completed the following additional discovery:

         STGC served its First Supplemental Disclosures on December 11, 2017.

         STGC served RUIZ with responses to RUIZ's written discovery ...


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