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Navigators Insurance Co. v. Sparta Insurance Co.

United States District Court, D. Nevada

May 16, 2018

NAVIGATORS INSURANCE COMPANY, Plaintiff,
v.
SPARTA INSURANCE COMPANY, Defendant. Deadline Current Deadline Date Extension Sought

          MURCHISON & CUMMING, LLP Michael J. Nuñez, Esq. Nevada Bar No. 10703 Tyler N. Ure, Esq. Nevada Bar No. 11730 350 Attorneys for Defendant

          MORALES, FIERRO & REEVES Ramiro Morales, Esq. Nevada Bar No. 7101 Attorneys for Plaintiff

          STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER DEADLINES (FIRST REQUEST)

         This Stipulation to modify the scheduling order is entered into by and between Plaintiff NAVIGATORS INSURANCE COMPANY (hereinafter "Plaintiff") and SPARTA INSURANCE COMPANY (hereinafter "Defendant"), by and through their attorneys of record, pursuant to LR 6-1(b) and LR 26(4) and based upon the following:

         (a) A statement of Discovery Completed to Dated:

         Plaintiff and Defendant have exchanged initial disclosures of documents and the names of individuals with knowledge of the facts pertaining to Plaintiff's claims against the Defendant. The Defendant has propounded written discovery requests to Plaintiff, including interrogatories and requests for production, and Plaintiff has served its responses to Defendant's interrogatories. The Plaintiff has propounded interrogatories and requests for production to Defendant.

         A specific description of the discovery that remains to be completed

. Defendant anticipates taking the deposition of Plaintiffs FRCP 30(b)(6) Person(s) with Knowledge.
. Plaintiff anticipates taking the depositions of Defendant's FRCP 30(b)(6) Person(s) with Knowledge.
. Defendant anticipates taking the deposition of Plaintiffs Expert(s).
. Plaintiff anticipates taking the deposition of Defendant's Expert(s).
. The Plaintiff anticipates issuing subpoenas to non-parties for business records.

         (b) The reason why discovery remaining was not completed within the time limits set by the discovery plan

         The parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested extension. The parties agree that, pending this Court's approval, extension of the discovery deadlines is appropriate, as the parties wish to further investigate this case, and potentially reach a resolutions prior to incurring fees and costs for extensive discovery. An extension is also necessary for the depositions of Defendant's and Plaintiff's FRCP 30(b)(6) Person(s) with Knowledge. Further, it has become apparent that between witness' travel plans over the summer and ...


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