United States District Court, D. Nevada
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
LAW GROUP Mark Hesiak Eric Hinckley, Esq. Nevada Bar No.
12398 Mark Hesiak, Esq. Nevada Bar No. 12397
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
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
LOCAL RULE 6-1 IS SATISFIED
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
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.
instant request comports with Local Rule 6-1, in that no
request is being made after the ...