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Platt v. National General Insurance Co.

United States District Court, D. Nevada

May 1, 2018

EARNEST PLATT, Plaintiff,
v.
NATIONAL GENERAL INSURANCE COMPANY, DOES I-X, and ROE CORPORATIONS I-X, inclusive, Defendants.

          RICHARD HARRIS LAW FIRM, TRAVIS H. DUNSMOOR, Attorneys for Plaintiff Earnest Platt

          ATKIN WINNER & SHERROD, THOMAS E. WINNER, Attorneys for Defendant National General Insurance Company

          STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER

         Defendant, NATIONAL GENERAL INSURANCE COMPANY, by and through their attorneys of record, Thomas E. Winner and Virginia T. Tomova of ATKIN WINNER & SHERROD, and Plaintiff, EARNEST PLATT, by and through his counsel, Travis Dunsmoor of the RICHARD HARRIS LAW FIRM, respectfully submit the following Stipulated Discovery Plan and Scheduling Order, pursuant to local rule 26.1(b) and Federal Rule of Civil Procedure 26(f).

         PROPOSED SCHEDULE

         1. Rule 26(f) Conference: This matter was initially filed in the Eighth Judicial District Court in Clark County, Nevada by the Plaintiff Earnest Platt on November 15, 2017. The case was styled Earnest Platt v. National General Insurance Company, Does I-X, and Roe Corporations I-X, inclusive, No. A-17-764747-C. The case was properly removed on January 11, 2018. Pursuant to Fed.R.Civ.P. 26(f), the parties held the initial discovery conference on March 21, 2018.

         2. Initial Disclosures: No. changes are necessary in the form or requirement for the disclosures under Fed.R.Civ.P.26(a). Plaintiff has not made his Initial List of Witnesses and Documents disclosure under Local Rule 26.1. Defendant made its Initial List of Witnesses and Documents disclosure under Local Rule 26.1 on or about March 22, 2018.

         3. Areas of Discovery: The parties need to conduct discovery regarding (a) the allegations in Plaintiffs Complaint and (b) Defendant's defenses.

         4. Discovery Plan: The Parties propose the following discovery plan:

a. Discovery Cut-off Date(s): L.R. 26(e)(1) provides that “unless the court orders otherwise, discovery periods longer than 180 days from the date the first defendant answers or appears will require special scheduling review.” The parties agree that there is no need for a special scheduling review. The parties further agree that discovery will be conducted within 180 days from the date of the filing of Defendant's Answer to Plaintiffs Complaint, which was filed on or about March 13, 2018. Therefore, all discovery shall be completed no later than September 10, 2018
b. Amending Pleadings or Adding Parties: Unless otherwise stated herein or ordered by the Court, the date for filing motions to amend the pleadings or to add parties shall not be later than ninety (90) days prior to the discovery cut-off date. Therefore, any such motion shall be filed no later than June 12, 2018.
c. Disclosure of Expert Witnesses: In accordance with Fed.R.Civ.P. 26(a)(2) and L.R. 26-1(3), disclosures identifying experts shall be made sixty (60) days prior to discovery cut-off date. Therefore, initial expert disclosures shall be made no later than July 12, 2018. Disclosures identifying rebuttal experts shall be made within thirty (30) days after the initial expert disclosures. Therefore, rebuttal expert disclosures shall be made no later than August 13, 2018.
d. Interim Status Report: Sixty (60) days prior to the close of discovery, the parties shall file an Interim Status Report, as required by LR 26-3, stating the time estimated for trial, three alternative dates for trial and whether trial will be proceeding or affected by substantive motions. Therefore, the Interim Status Report shall be filed no later than July 12, 2018.
e. Dispositive Motions: Dispositive motions must be filed within thirty (30) days after the close of discovery. Therefore, such motions shall be filed no later than October 10, 2018.
f. Pre-Trial Order: The parties will prepare a Joint Pre-Trial Order on or before November 12, 2018, which is no more than thirty (30) days after the date set for filing dispositive motions in the case. This deadline will be suspended if dispositive motions are timely filed until thirty (30) days after the decision of the dispositive motions or until further order by the Court. The disclosure ...

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