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Androwski v. MID Century Insurance Co.

United States District Court, D. Nevada

February 16, 2018

ADRIENNE ANDROWSKI, an individual; Plaintiff,
v.
MID CENTURY INSURANCE COMPANY; and DOES I through X, inclusive; and ROE CORPORATIONS I through V, inclusive; Defendants.

          ATKINSON WATKINS & HOFFMANN, LLP MATTHEW W. HOFFMANN, ESQ. Attorney for Plaintiff Attorney

          LAW OFFICES OF KARL H. SMITH SARAH SMITH, ESQ. Attorney for Defendant.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         COME NOW, Plaintiff, ADRIENNE ANDROWSKI (hereinafter referred to as "Plaintiff), by and though her attorneys of record, MATTHEW W. HOFFMANN, ESQ. and the law firm of ATKINSON WATKPNS & HOFFMANN, LLP, and Defendant, MID CENTURY INSURANCE COMPANY (hereinafter referred to as "Defendant"), by and through its attorneys of record, SARAH SMITH, ESQ. and the LAW OFFICES OF KARL H. SMITH, and hereby stipulate, agree and make this joint application to extend the discovery deadlines for a period of thirty (30) days, from April 16, 2018 to May 16, 2018. This stipulation is made and based upon the following facts and for the following reasons:

         I. INTRODUCTION

         This action arises from an automobile collision that occurred on November 6, 2015. Plaintiff was traveling northbound on US95, south of the SR582 northbound on-ramp in the number one travel lane. The adverse driver, Constance Stozer, was traveling behind Plaintiff. At said place and time, the adverse driver negligently and carelessly slammed into the rear of Plaintiff s vehicle.

         The adverse driver's insurance policy did not provide sufficient funds with which to compensate Plaintiff for her injuries and damages. Plaintiff filed a claim for Underinsured Motorists Benefits with Defendant pursuant to the subject policy, and Defendant failed to perform their duties under subject policy by failing to make a reasonable settlement offer or to provide any explanation for their unreasonable offer in a timely manner.

         II. DISCOVERY COMPLETED TO DATE

         On November 7, 2017, the Court signed the parties' Stipulated Discovery Plan and Scheduling Order, setting forth the following discovery deadlines:

• Initial Expert Disclosure Deadline

February 15, 2018

• Rebuttal Expert Disclosure Deadline

March 16, 2018

• Discovery cutoff

April 16, 2018

• Last day to file dispositive motions

May 16, 2018

• Last day to file Pretrial Order

June 15, 2018

         Trial for this matter has not yet been set.

         To date, the parties have completed the following discovery:

1. Plaintiff served her Initial Disclosures Pursuant to Fed.R.Civ.P. 26 on October 31, 2016.
2. Defendant served its Initial Disclosures Pursuant to Rule 26(a)(1) on November 7, 2017.
3. A Stipulated Discovery Plan and Scheduling Order was submitted on November 6, 2017 and approved by this Honorable ...

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