United States District Court, D. Nevada
ATKINSON WATKINS & HOFFMANN, LLP MATTHEW W. HOFFMANN,
ESQ. Attorney for Plaintiff Attorney
OFFICES OF KARL H. SMITH SARAH SMITH, ESQ. Attorney for
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
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:
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.
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.
DISCOVERY COMPLETED TO DATE
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
for this matter has not yet been set.
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