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Vries v. Allstate Insurance Co.

United States District Court, D. Nevada

January 23, 2018

JOHN DE VRIES, an individual, Plaintiff,
v.
ALLSTATE INSURANCE COMPANY; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.

          KEATING LAW GROUP, JOHN T. KEATING Nevada Attorneys for Defendant Allstate Insurance Company.

          SANTORO WHITMIRE, JASON D. SMITH, ESQ, Attorneys for Plaintiff John De Vries.

          STIPULATION TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES BY 30 DAYS (SECOND REQUEST)

         Pursuant to LR 6-1 and LR 26-4, Defendant ALLSTATE INSURANCE COMPANY (Defendant), and Plaintiff JOHN DE VRIES (Plaintiff), by and through their respective counsel of record, respectfully submit the following stipulation requesting a thirty (30) day extension of the current order deadlines. The current discovery cut-off is April 9, 2018. This stipulation is being made at least 21 days before expiration of the current discovery cut-off and is being entered into in good faith and not for the purpose of delay. In support of this Stipulation and Request, the parties state as follows:

         I. Introduction

         This case is a bad faith action brought by Plaintiff for alleged damages suffered as a result of a vehicle theft loss on December 2, 2016. Plaintiff filed a complaint in State Court on June 14, 2017, and on June 30, 2017, Defendant removed this matter to Federal Court. Defendant Answered on July 11, 2017. The Second Amended Stipulated Discovery Plan and Scheduling Order was entered on August 24, 2017, and the dates were extended by ninety (90) days via stipulation and order entered on October 27, 2017. This is the second request to extend the deadlines.

         II. Discovery Status

         A. Discovery that has been completed.

1. Plaintiff served his Initial Disclosures pursuant to FRCP 26(a)(1) on August 31, 2017.
2. Defendant served its Initial Disclosures pursuant to FRCP 26(a)(1) on September 12, 2017.
3. The Parties continue to supplement their respective Initial Disclosures.
4. Plaintiff served his First Set of Interrogatories and First Set of Requests for Production on September 11, 2017.
5. Defendant served its responses to Plaintiff's discovery requests on November 14, 2017.
6. Defendant served its First Set of Interrogatories and First Set of Requests for Production of Documents ...

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