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Rood v. Liberty Insurance Underwriters, Inc.

United States District Court, D. Nevada

December 28, 2017

MARTIN S. ROOD, Plaintiff,
v.
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)

         Plaintiff, 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.

         I. INTRODUCTION.

         On 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 following dates:

(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).

         II. STATEMENTS PECIFYING THE DISCOVERY COMPLETED

         Pursuant 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.

         A. ...


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