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Hamilton v. James River Insurance Co.

United States District Court, D. Nevada

May 1, 2018

CHRISTOPHER HAMILTON, an individual, Plaintiff,
v.
JAMES RIVER INSURANCE COMPANY, an Illinois corporation; DOES I through X, and ROE CORPORATIONS I through X, inclusive, Defendants.

          BREMER, WHYTE, BROWN & O'MEARA, LLP Lucian J. Greco, Jr, Esq. Nevada State Bar No. 10600 Jared G. Christensen, Esq. Nevada State Bar No. 11538 Deleela M. Weinerman Nevada State Bar No. 13985 Attorneys for Defendant, James River Insurance Company

          LOWE LAW GROUP Mark Hesiak Eric Hinckley, Esq. Nevada Bar No. 12398 Mark Hesiak, Esq. Nevada Bar No. 12397

          BREMER WHYTE BROWN & O'MEARA LLP Lucian J. Greco, Jr, Esq. Nevada State Bar No. 10600 Jared G. Christensen, Esq. Nevada State Bar No. 11538 Deleela M. Weinerman Nevada State Bar No. 13985 Attorneys for Defendant, James River Insurance Company

          STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST)

         All of the parties hereto, and for good cause described in this stipulation, and in accord with Local Rule 6-1 and Local Rule 26-4, the parties hereby request this Honorable Court to adopt and approve this stipulated extension to the discovery plan, and continue the discovery deadlines for 90 days as requested herein.

         I. LOCAL RULE 6-1 IS SATISFIED

         This is the first request for extension of discovery deadlines filed by the parties. Pursuant to the Stipulated Discovery Plan and Order dated March 9, 2018, the following dates govern for purposes of discovery:

1. Discovery Cutoff Dated: August 8, 2018
2. Motions to amend pleadings and add parties: May 10, 2018
3. Expert Designations: June 9, 2018
4. Rebuttal Expert Designations: July 9, 2018
5. Dispositive Motions: September 7, 2018
6. Joint Pre-Trial Order: October 8, 2018

         The parties have been working in good faith to reach an amicable resolution. However, Plaintiff is still undergoing medical treatment and as such, is in the process of compiling complete information for initial disclosures and supplying requested HIPPA authorizations. As such, the parties need additional time to prepare for the disclosure of initial experts. Accordingly, the parties are requesting a 90-day extension to all discovery deadlines.

         The instant request comports with Local Rule 6-1, in that no request is being made after the ...


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