United States District Court, D. Nevada
T. BRENNER, ESQ. Nevada Bar No. 8386 JAMIE K. COMBS, ESQ.
Nevada Bar No. 13088 Akerman LLP Attorneys for Property and
Casualty Insurance Company of Hartford
BERNSTEIN & POISSON Karlie M. Gabour SCOTT L. POISSON,
ESQ. Nevada Bar No. 10188 KARLIE M. GABOUR, ESQ. Nevada Bar
No. 13123 Attorneys for Mary Jean Lambert
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
Property and Casualty Insurance Company of Hartford
(Defendant), incorrectly named as Hartford Underwriters
Insurance Company, and plaintiff Mary Jean Lambert
(Plaintiff), respectfully submit the following stipulation
requesting a sixty (60) day extension of the current
scheduling order deadlines.
case is a dispute arising out of an automobile insurance
policy. Plaintiff allegedly suffered injuries as a result of
a motor vehicle collision on April 11, 2012, and made a claim
on her insurance policy. Plaintiff filed a complaint in State
Court on April 17, 2017, alleging breach of contract,
contractual breach of implied covenant and good faith and
fair dealing, and unfair claims practices. On May 26, 2017,
Defendant removed this matter to Federal Court. A discovery
plan and scheduling order was entered on August 24, 2017 [ECF
Docket #12]. A stipulation and order to extend discovery
deadlines was entered on November 29, 2017 [ECF Docket #19].
November 29, 2017, the court entered a stipulation and order
to extend discovery deadlines which set the following
(a). Discovery Cut Off: Monday, April 2, 2018.
(b). Motions to amend pleadings or add parties: No extension
(c). Initial Expert Disclosures: Friday, February 2, 2018.
(d). Rebuttal Expert Disclosures: Monday, March 5, 2018.
(e). Interim Status Report: Friday, February 2, 2018.
(f). Dispositive Motions: Tuesday, May ...