United States District Court, D. Nevada
MARTIN S. ROOD, Plaintiff,
LIBERTY INSURANCE UNDERWRITERS, INC., a Stock Insurance Company, a/k/a/ Liberty Mutual Group; DOES 1 through 5, and ROE COROPORATIONS 1 through 5, Defendant(s).
NEILSON P.C. DAVID A. CLARK Nevada Bar No. 4443 ERIC N. TRAN
Nevada Bar No. 11876 Attorneys for Defendant Liberty
Spencer M. Judd Spencer M. Judd, Esq. Attorneys for Plaintiff
STIPULATION AND (PROPOSED)
ORDER TO EXTEND DISCOVERY DEADLINES
Martin S. Rood ("Plaintiff'), and Defendant, Liberty
Insurance Underwriters, Inc. ("Defendant"), by and
through their respective attorneys of record, respectfully
submit the following Stipulation and [Proposed] Order
requesting to extend the discovery deadline by Sixty (60)
days of the current scheduling order deadlines. This is the
parties' third and final request for an extension of the
deadlines in this case.
December 29, 2017, the Court entered a Stipulation and Order
to Extend Discovery Deadlines (Second Request); (ECF No. 21)
filed by the parties. The Stipulation and Order set the
(a) Discovery Cut-off: April 2, 2018
(b) Final Date to File Dispositive Motions: May 7, 2018 (May
5, 2018 falls on a Saturday)
(c) Pretrial Order: June 7, 2018 (not later than 30 days
after the date for dispositive motions, unless dispositive
motions are filed).
STATEMENT SPECIFYING THE DISCOVERY COMPLETED
to the requirements of LR6-1 and LR26-4, the parties provide
the Court with the following information in support of their
stipulation to extend discovery.
Initial Disclosure served by Plaintiff and Defendant;
Written Discovery (Interrogatories, Requests for Admissions,
and Requests for Production of Documents) propounded by
Plaintiff and responded to by Defendant.
Written Discovery (Interrogatories, and Requests for
Production of Documents) propounded by Defendant ...