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Seegmiller v. State Farm Mutual Automobile Insurance Co.

United States District Court, D. Nevada, Southern Division

November 18, 2019

CLARK SEEGMILLER, Plaintiff,
v.
STATE FARM MUTAL AUTOMOBILE INSURANCE COMPANY; DOES I through X, inclusive, and ROE CORPORATIONS I through X, inclusive, Defendants.

          TITOLO LAW OFFICE TIMOTHY R. TITOLO, Esq. Nevada Bar No. 3617 Attorneys for Plaintiff

          LEWIS BRISBOIS BISGAARD SMITH LLP ROBERT W. FREEMAN, ESQ. Nevada Bar No. 03062 PAMELA L. McGAHA, ESQ. Nevada Bar No. 8181 MAYRA SALINAS-MENJIVAR Nevada Bar No. 14607 Attorneys for Defendants

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES [FIRST REQUEST]

         Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case sixty (60) days, up to and including Monday, April 6, 2020. In addition, the parties request that the all other future deadlines contemplated by the Discovery Plan and Scheduling Order be extended pursuant to Local Rule. In support of this Stipulation and Request, the parties state as follows:

         1. On June 27, 2019, Plaintiff filed her Complaint in the Eight Judicial District Court.

         2. On July 11, 2019, Plaintiff served the Complaint on the Nevada Department of Business and Industry, Division of Insurance.

         3. On August 2, 2019, Defendant filed its Petition for Removal.

         4. On August 9, 2019, Defendant filed its Answer to Complaint.

         5. On September 18, 2019, the parties conducted an initial FRCP 26(f) conference 6. On September 24, 2019, the Court entered the Stipulated Discovery Order.

         7. On September 30, 2019, Plaintiff served his FRCP 26 Initial Disclosures on Defendant.

         8. On October 4, 2019, Defendant served its FRCP 26 Initial Disclosures on Defendant.

         9. On November 6, 2019, Defendant served written discovery on Plaintiff. Plaintiff's Responses are due on December 11, 2019.

         DISCOVERY REMAINING

         1. The parties will continue ...


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