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Platt v. National General Insurance Co.

United States District Court, D. Nevada

July 12, 2018

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

          ATKIN WINNER & SHERROD, THOMAS E. WINNER NEVADA BAR NO. 5168 VIRGINIA T. TOMOVA NEVADA BAR NO.12504 ATTORNEYS FOR DEFENDANT

          RICHARD HARRIS LAW FIRM, TRAVIS H. DUNSMOOR NEVADA BAR NO. 13111 ATTORNEYS FOR PLAINTIFF

          STIPULATION AND ORDER TO EXTEND DEADLINES FOR DISCOVERY AND DISCLOSURE OF EXPERTS

         IT IS HEREBY STIPULATED by and between THOMAS E. WINNER and VIRGINIA T. TOMOVA, attorneys for Defendant, NATIONAL GENERAL INSURANCE COMPANY, and TRAVIS H. DUNSMOOR, attorney for Plaintiff EARNEST PLATT, pursuant to LR 26-4.

         1. DISCOVERY COMPLETED

         Both Plaintiff and Defendant served their initial FRCP 26(f) document and witness disclosures. Defendant has served Plaintiff with written interrogatories and requests for production, and Plaintiff has answered.

         2. DISCOVERY TO BE COMPLETED

         Counsel for NATIONAL GENERAL INSURANCE COMPANY has scheduled the deposition of the Plaintiff for August 27, 2018. Further, the parties will also seek to depose the retained expert witnesses that will be disclosed by the parties.

         Defendant will complete the afore-mentioned depositions; will depose Plaintiff's designated expert witnesses once identified, and will request Plaintiff undergo an examination pursuant to FRCP 35(a). Counsel understands that the treating physicians are typically booked for depositions two to three months in advance, and so coordinating these depositions will take longer than initially anticipated.

         3. WHY DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER

         The parties have been diligent in serving their initial disclosures, in reviewing those Disclosures, and in pursuing Written Discovery. The parties believe, however, that meaningtful depositions should take place after August 27, 2018. Plaintiff Earnest Platt's deposition is scheduled to take place on August 27, 2018. The number of Depositions that need to be taken, together with the expected complexities in the scheduling of the Depositions, necessitate that the Deadline for Discovery be extended as requested herein. In addition, meaningful evaluation by the parties' experts will require the Experts' review of the Depositions of fact witnesses, necessitating that the Deadline for Disclosure of Experts and Expert Reports be correspondingly extended.

         4. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY

         The parties propose the following schedule:

ACTIVITY

CURRENT DEADLINE

PROPOSED DEADLINE

Interim Status Report

July 12, 2018

October 12, 2018

Initial Expert Disclosures

July 12, 2018

October 12, 2018

Rebuttal Expert Disclosures

August 13, 2018

September 13, 2018

Deadline to Complete Discovery

September 10, 2018

December 10, 2018

Dispositive Motions

October 10, 2018

January 10, 2019

Pretrial Order

November 12, 2018

February 12, 2019


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