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Grogan v. State Farm Mutual Automobile Insurance Co.

United States District Court, D. Nevada

February 13, 2018

PAMELA GROGAN, individually, Plaintiffs,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, an entity licensed to do business in Nevada; DOES I through X; and ROE CORPORATIONS, XI through XX, inclusive, Defendants.

          MARK G. HENNESS, ESQ. Nevada Bar No. 5842 JACOB S. SMITH, ESQ. Nevada Bar No. 10231 HENNSS & HAIGHT Attorneys for Plaintiff

          RANALLI ZANIEL FOWLER & MORAN, LLC BENJAMIN J. CARMAN, ESQ. GEORGE M. RANALLI, ESQ. Nevada Bar No. 5748 BENJAMIN J. CARMAN, ESQ. Nevada Bar No. 12565 Attorneys for Defendant

          STIPULATION AND ORDER TO EXTEND DISOVERY DEADLINES (FIRST REQUEST)

         COMES NOW, Plaintiff, PAMELA GROGAN, by and through her counsel of record, MARK G. HENNESS, ESQ. and JACOB S. SMITH, ESQ. of the law firm of HENNESS & HAIGHT and Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by and through its counsel of record, BENJAMIN J. CARMAN, ESQ. of the law firm of RANALLI ZANIEL FOWLER & MORAN, and submit the following stipulation and order to extend discovery deadlines pursuant to LR 26-4 as follows:

         1. Summary of Discovery Completed

         All parties have provided initial witness lists and documents pursuant to FRCP 26 and supplements thereto. Plaintiff has executed authorizations served by Defendant. Plaintiff is presently working to schedule the depositions of State Farm Adjuster, Kim Korich, as well as the 30(b)(6) witness(es) of State Farm. The parties are working to schedule the deposition of Plaintiff.

         2. Discovery Remaining

         The depositions of Plaintiff and Plaintiff's treating doctors must be completed. Written discovery may be propounded by both parties. Depositions of non-party witnesses and the parties' expert witnesses (once disclosed) need to be taken.

         3. Reason Why Discovery Was Not Completed

         Discovery in this matter is currently scheduled to close on April 13, 2018. Additional time is required to work through scheduling issues so that discovery may be completed. The parties have required additional time in order to coordinate the depositions of the Defendant's employees and corporate representatives. This is the parties' first request for an extension of discovery deadlines in this matter; therefore, the parties have agreed to an extension of the discovery deadlines to enable them to complete the remaining discovery.

         4. Proposed Schedule for Completing Discovery

         Accordingly, the parties respectfully request that this Court enter an order setting the following discovery plan and scheduling order dates:

Event

Former Deadline

New Deadline

Discovery Deadline

04/13/18

06/13/18

Motions to Amend Pleadings and Add Parties

01/12/18

03/12/18

Initial Expert Designations

02/12/18

04/12/18

Rebuttal Expert Designations

03/14/18

05/14/18

Dispositive Motions

05/14/18

07/13/18

Joint Pre-Trial Order

06/13/18

08/13/18

         Counsel further states that the requested extension of the discovery deadline is not intended for purposes of delay, but ...


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