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Stewart v. State Farm Mutual Automobile Insurance Co.

United States District Court, D. Nevada

April 6, 2018

KORI DIANE STEWART, Plaintiff,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign corporation; DOES 1 through 10; ROE ENTITIES 1 through 10; ABC LIMITED LIABILITY COMPANIES, inclusive, jointly and severally, Defendants.

          Mainor Wirth, LLP, JAMES D. URRUTIA, ESQ., KATIE E. GOLDBERG, ESQ., Attorneys for Plaintiff.

          Ranalli Zaniel Fowler & Moran, LLC, GEORGE M. RANALLI, ESQ., BENJAMIN J. CARMAN, ESQ. Attorneys for Defendant.

          PROPOSED STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) [Submitted in Compliance with LR 26-4]

         The parties, by and through their respective counsel of record, stipulate to extend discovery in the above-referenced action, and seek an Amended Scheduling Order setting new discovery deadlines as follows:

         I. Local Rule 6-1

         Under LR 6-1(b) every stipulation to extend time must inform the court of any previous extensions granted and state the reasons for the extension requested.

         a. The Requirements of Local Rule 6-1 Are Satisfied

         This is the first request for extension filed by the parties.

         II. Local Rule 26-4

         Under LR 26-4, an application to extend any deadline set by the discovery plan, scheduling order, or other order must be received no later than twenty-one (21) days before the expiration of any such deadline. Any request to extend any such deadline must be supported by a showing of good cause. Any request made after the expiration of the subject deadline shall not be granted unless the movant demonstrates that the failure to act was the result of excusable neglect.

         a. The Time Requirements of Local Rule 26-4 Are Satisfied

         The current discovery cut-off date is June 22, 2018. The primary date the parties wish to extend is that of initial and rebuttal expert disclosures which is April 23, 2018, which satisfies the time period requirements.

         III. There is Good Cause for the Extension

         This is a civil action alleging breach of contract, breach of the covenant of good faith and fair dealing, and alleged violations of NRS 686A.310. Both parties require additional time to obtain testimony from multiple insurance adjusters, from the FRCP 30(b)(6) designee(s) of Defendant, and from Plaintiff. These depositions were unable to be coordinated prior to the initial expert disclosure deadline of April 23, 2018, due to the availability and trial calendars of Plaintiff's and Defendant's counsel and deponents. The current scheduling order requires initial experts to be disclosed no later than April 23, 2018. However, the insurance adjusters were not available until mid-April 2018, to appear in Washington state for depositions, and the FRCP 30(b)(6) designee was not available until June 2018.

         Neither party is able to submit all necessary documents to their respective experts and to obtain the requisite expert reports and meet this current deadline because the depositions are not occurring until April 18, 2018; April 19, 2018; and June 7, 2018. In the interests of preserving trial upon the ...


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