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Lambert v. Property and Casualty Insurance Co. of Hartford

United States District Court, D. Nevada

February 5, 2018

MARY JEAN LAMBERT, Plaintiff,
v.
PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD; HARTFORD UNDERWRITERS INSURANCE COMPANY, companies and entities licensed to do business in Arizona and Nevada; DOES 1 through 10; XYZ Corporations 11 through 20; and ABC Limited Liability Companies 21 through 30, inclusive, Defendants.

          DARREN 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 (SECOND REQUEST)

         Defendant 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.

         I. Introduction.

         This 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].

         II. Discovery Status.

         On November 29, 2017, the court entered a stipulation and order to extend discovery deadlines which set the following deadlines:

(a). Discovery Cut Off: Monday, April 2, 2018.
(b). Motions to amend pleadings or add parties: No extension requested.
(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 ...

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