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Doremus v. American Family Mutual Insurance Co.

United States District Court, D. Nevada

March 13, 2018

FRED DOREMUS, individually; and LINDA DOREMUS, individually, Plaintiffs,
v.
AMERICAN FAMILY MUTUAL INSURANCE COMPANY, a foreign entity; DOES I through X; and ROE CORPORATIONS, XI through XX, inclusive, Defendants.

          Kevin C. Barrett, State Bar, 8959 BARRETT MATURA, Attorneys for Defendant American Family Mutual Insurance Company

          Jacob Smith, HENNESS & HAIGHT, Attorneys for Plaintiffs Fred & Linda Doremus

          STIPULATION AND ORDER FOR EXTENSION OF REMAINING DEADLINES [SECOND REQUEST]

         Pursuant to Federal Rule of Civil Procedure 29(b) and Local Rules 6-1, 7-1, and LR 26-4, the parties hereby submit the following Stipulation and Order for Extension of Remaining Deadlines (Second Request) to extend the discovery deadlines and all related case management deadlines, as set forth in the Court's Scheduling Order [Doc. 13] and Order granting Stipulation to Extend Discovery Deadline [Doc. 17], by approximately 90 days.

         I. STATUS OF DISCOVERY EFFORTS TO DATE

         The parties have conducted the following discovery to Dated:

• Disclosure statements have been exchanged.
• Defendant served Plaintiffs with Interrogatories and Requests for Production on September 19, 2017.
• Plaintiffs have responded to Interrogatories and Requests for Production on October 23, 2017.
• Defendant issued subpoenas duces tecum to Plaintiffs' medical providers in November, 2017.
• Some medical records have been produced by Plaintiffs' medical providers, but not all.
• Plaintiffs issued Interrogatories, Requests for Production, and Requests for Admission to Defendant on February 6, 2018.
• Defendant's responses to Plaintiffs' Interrogatories, Requests for Production, and Requests for Admission will be filed on March 12, 2018.
• Plaintiffs have taken the depositions of the claim handlers involved in this matter and some ...

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