United States District Court, D. Nevada
T. BRENNER, ESQ. Nevada Bar No. 8386 JAMIE K. COMBS, ESQ.
Nevada Bar No. 13088 AKERMAN LLP Attorneys for Property and
Casualty Insurance Company of Hartford
L. POISSON, ESQ. Nevada Bar No. 10188 KARLIE M. GABOUR, ESQ.
Nevada Bar No. 13123 Attorneys for Mary Jean Lambert
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
Property and Casualty Insurance Company of Hartford
(Defendant), incorrectly named as Hartford
Underwriters Insurance Company, and plaintiff Mary Jean
Lambert (Plaintiff), respectfully submit the
following stipulation requesting a sixty (60) day extension
of the current scheduling order deadlines.
case is a dispute arising out of an automobile insurance
policy. Plaintiff allegedly suffered injuries as a result of
a motor vehicle collision on April 11, 2012, and made a claim
on her insurance policy. Plaintiff filed a complaint in State
Court on April 17, 2017, alleging breach of contract,
contractual breach of implied covenant and good faith and
fair dealing, and unfair claims practices. On May 26, 2017,
Defendant removed this matter to Federal Court. A discovery
plan and scheduling order was entered on August 24, 2017 [ECF
Docket #12]. An order to extend discovery deadlines was
entered on November 29, 2017 [ECF Docket #19], February 5,
2018 [ECF Docket # 22], and April 3, 2018 [ECF Docket #24].
April 3, 2018, the court entered an order to extend discovery
deadlines which set the following deadlines:
(a). Discovery Cut Off: Tuesday, July 31, 2018.
(b). Motions to amend pleadings or add parties: No extension
(c). Initial Expert Disclosures: Friday, June 1, 2018.
(d). Rebuttal Expert Disclosures: Monday, July 2, 2018.
(e). Interim Status Report: Friday, June 1, 2018.
(f). Dispositive Motions: Thursday, August 30, 2018.
(g). Pretrial Order: Tuesday, Monday, October 1, 2018.
(h). Extensions or Modifications of the Discovery Plan and
Scheduling Order: Tuesday, July 10, 2018.
6, 2018, the court entered an order to extend expert
disclosure deadlines ...