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LLC v. New York Marine and General Insurance Co.

United States District Court, D. Nevada

November 18, 2019

LAS VEGAS 360, LLC Plaintiff,
v.
NEW YORK MARINE AND GENERAL INSURANCE COMPANY., et al., Defendants.

          RESNICK & LOUIS, P.C Athanasia Dalacas, Esq., Bar No. 9390 Attorneys for Defendant New York Marine and General Insurance Company

          COHEN|JOHNSON|PARKER|EDWARDS (with permission) JAMES L. EDWARDS, ESQ. Nevada Bar No. 04256 Attorneys for Plaintiff

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

         DEFENDANT NEW YORK MARINE AND GENERAL INSURANCE COMPANY and PLAINITFF LAS VEGAS 360, by and through counsel undersigned, respectfully submit the following stipulation requesting a sixty (60) day stay of all case deadlines in order to allow for continued settlement efforts and a formal mediation with an agreed upon Mediator.

         I. INTRODUCTION.

         This case is a dispute arising out of allegations of bad faith in the adjustment of certain property claims. On December 12, 2018, the Early Case Conference was held with all parties present. The Joint Case Conference Report was filed on January 10, 2019, permitting the parties to begin discovery. A discovery plan and scheduling order was entered on May 22, 2019. On September 17, 2019, a Stipulation and Order to Extend Certain Scheduling Order Deadlines (First Request) was entered.

         II. DISCOVERY STATUS.

         Pursuant to the September 17, 2019 Stipulation and Order to Extend Certain Scheduling Order Deadlines (First Request), the following deadlines are in effect:

Event

Current Date

Discovery Cutoff

January 20, 2019

Initial Expert Disclosures

November 18, 2019

Last Day to File Interim Status Report

November 18, 2019

Rebuttal Expert Disclosures

December 18, 2019

Last Day to File Dispositive Motions

February 18, 2019

Last Day to File Pretrial Order

March 20, 2020

         III. DISCOVERY THAT HAS BEEN COMPLETED.

         1. Defendant served its Initial Rule 26(A)(1) Disclosure Statement on July 1, 2019;

         2. Defendant served Interrogatories and Requests for Production of Documents upon Plaintiff on July 12, 2019;

         3. Plaintiff severed its Initial Rule 26(A)(1) Disclosure Statement on August 14, 2019; and

         4. Plaintiff served its answers to the interrogatories on September 10, 2019 and Defendant has still not yet served any answers to Plaintiff's Requests for Production of Documents;

         IV. DISCOVERY ...


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