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Rood v. Liberty Insurance Underwriters, Inc.

United States District Court, D. Nevada

March 26, 2018

MARTIN S. ROOD, Plaintiff,
v.
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).

          LIPSON NEILSON P.C. DAVID A. CLARK Nevada Bar No. 4443 ERIC N. TRAN Nevada Bar No. 11876 Attorneys for Defendant Liberty Insurance Underwriters

          Spencer M. Judd Spencer M. Judd, Esq. Attorneys for Plaintiff

          STIPULATION AND (PROPOSED) ORDER TO EXTEND DISCOVERY DEADLINES

         Plaintiff, 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.

         I. INTRODUCTION.

         On 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 following dates:

(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).

         II. STATEMENT SPECIFYING THE DISCOVERY COMPLETED

         Pursuant 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.

         A, Discovery Completed.

         1. Initial Disclosure served by Plaintiff and Defendant;

         2. Written Discovery (Interrogatories, Requests for Admissions, and Requests for Production of Documents) propounded by Plaintiff and responded to by Defendant.

         3. Written Discovery (Interrogatories, and Requests for Production of Documents) propounded by Defendant ...


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