United States District Court, D. Nevada
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)
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:
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.
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
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 ...