United States District Court, D. Nevada
MARTIN S. ROOD, Plaintiff,
LIBERTY INSURANCE UNDERWRITERS, INC., a Stock Insurance Company, a/k/a/ Liberty Mutual Group; DOES 1 through 5, and ROE COROPORATIONS 1 through 5, Defendants.
LIPSON, NEILSON, COLE, SELTZER & GARIN, P.C. DAVID A.
CLARK Nevada Bar No. 4443 ERIC N. TRAN Nevada Bar No. 11876
Attorneys for Defendant Liberty Insurance Underwriters
Spencer M. Judd, Esq. Attorneys for Plaintiff
STIPULATION AND (PROPOSED)
ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)
Martin S. Rood (“Plaintiff”), and Defendant,
Liberty Insurance Underwriters, Inc.
(“Defendant”), by and through their respective
attorneys of record, respectfully submit the following
Stipulation and [Proposed] Order requesting to extend the
discovery deadline by Sixty (60) days of the current
scheduling order deadlines. This is the parties' second
request for an extension of the deadlines in this case.
October 27, 2017, the Court entered a Stipulation and Order
to Extend Discovery Deadlines (First Request); (ECF No. 20)
filed by the parties. The Stipulation and Order set the
(a) Discovery Cut-off: February 1, 2018
(b) Deadline for Initial Expert Disclosures: December 4, 2017
(c) Deadline for Rebuttal Expert Disclosures: January 3, 2018
(d) Interim Status Report: December 4, 2017
(e) Final Date to File Dispositive Motions: March 5, 2018
(f) Pretrial Order: April 4, 2018 (not later than 30 days
after the date for dispositive motions, unless dispositive
motions are filed).
STATEMENTS PECIFYING THE DISCOVERY
to the requirements of LR6-1 and LR26-4, the parties provide
the Court with the following information in support of their
stipulation to extend discovery in this matter.