United States District Court, D. Nevada
ROBERT NUNEZ RUIZ, an Individual; and TERESA LYNN RUIZ, an Individual, Plaintiffs,
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
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
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:
STATEMENT PURSUANT TO LR 26-4:
Discovery Completed To Date.
served their Initial Disclosures on October 14, 2017.
served its Initial Disclosures on September 13, 2017.
served its First Set of Interrogatories, Requests for
Production, and Requests for Admission to STGC on October 19,
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
Discovery Completed After The Court's First, 90-day
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:
served its First Supplemental Disclosures on December 11,
served RUIZ with responses to RUIZ's written discovery