United States District Court, D. Nevada
W. FREEMAN, ESQ. CHERYL A. GRAMES, ESQ. LEWIS BRISBOIS
BISGAARD & SMITH LLP Attorneys for Defendant State Farm
Mutual Automobile Insurance Company
D. Powell, Esq. Michael A. Kristof, Esq. THE POWELL LAW FIRM
Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
to LR 6-1 and LR 26-4, the parties, by and through their
respective counsel of record, hereby stipulate and request
that this Court extend discovery in the above-captioned case
ninety (90) days, up to and including Tuesday, June 5, 2018.
In addition, the parties request that the all other future
deadlines contemplated by the Discovery Plan and Scheduling
Order be extended pursuant to Local Rule. In support of this
Stipulation and Request, the parties state as follows:
1. On October 31, 2016, Plaintiff filed his Complaint in the
Eight Judicial District Court. (ECF No. 1, Ex. A).
2. On January 9, 2017, Plaintiff served the Complaint on the
Nevada Department of Business and Industry, Division of
3. On February 10, 2017, Defendant filed its Petition for
4. On February 17, 2017, Defendant filed its Answer to
Complaint. (ECF No. 6).
5. On March 10, 2017, the parties conducted an initial FRCP
26(f) conference and submitted a Stipulated Discovery Plan
and Scheduling Order (the “Order”) for the
Court's approval. (ECF No. 10).
6. On March 29, 2017, the Court entered the Stipulated
Scheduling Order. (ECF No. 11).
7. On May 10, 2016, Plaintiff propounded written discovery
upon Defendant. Defendant served its responses on June 27,
8. On June 14, 2016, Defendant propounded written discovery
upon Plaintiff. Plaintiff served his responses on July 31,
9. On June 16, 2017, the parties filed a Second Request to
Extend Discovery Deadlines. (ECF No. 13).
10. On June 19, 2017, the Court issued its Order extending
the discovery deadlines. (ECF No. 14).
11. On September 18, 2017, the parties filed a Third Request
to Extend Discovery ...