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Yu v. Travelers Casualty and Surety Company of America

United States District Court, D. Nevada

December 5, 2019

SUEMIN YU, individually, Plaintiff,
v.
TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA; DOES I through X; and ROE CORPORATIONS XI through XX, inclusive, Defendants.

          HALL JAFFE & CLAYTON, LLP MICHAEL R. HALL Nevada Bar No. 005978 STEPHEN D. STEELE Nevada Bar No. 013965 Attorneys for Defendant

          HICKS & BRASIER, PLLC STEVEN M. ROGERS Nevada Bar No. 010975 Attorneys for Plaintiff

          STIPULATION AND [PROPOSED] ORDER TO STAY DISCOVERY PENDING MEDIATION

         Plaintiff SUEMIN YU (“Plaintiff”), and Defendant TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA (“Defendant”), by and through their respective counsel of record, hereby stipulate as follows:

         1. This case involves a UM/UIM breach of contract action deriving from an automobile accident that occurred on May 27, 2015, wherein Plaintiff's vehicle was struck by another vehicle that was uninsured. The complaint alleges that as a result of the accident Plaintiff has sustained physical injuries, and will require future medical care. According to Plaintiff's October 26, 2016, demand letter, Plaintiff has incurred over $61, 503.36 in past medical specials, and has been recommended to undergo future chiropractic care, which will cost, at a minimum, approximately another $1, 000.00 in future medical treatment; thus, the claimed medical specials alone is over $62, 000.00 As a result of the collision, Plaintiff alleges muscle spasms, radicular pain, cervical sprain/strain, and limited range of motion. Through this lawsuit, Plaintiff is seeking payment of the entire $250, 000 UIM policy limit from Travelers.

         2. This matter has been extensively litigated. Discovery completed to date includes completed written discovery requests, along with supplemental responses provided by Plaintiff, the deposition of Plaintiff, as well as multiple supplemental disclosures by Defendant.

         3. To date, the parties have not engaged in any form of alternative dispute resolution or otherwise shared meaningful settlement discussions. However, both parties agree that the case has reached a juncture in which substantive settlement discussion may result in the complete resolution of the case. To that end, the parties have agreed and scheduled private mediation with Jennifer Togliatti on January 16, 2020. Although neither party can commit that a settlement will be reached, both parties attest that they will enter into and participate in the mediation in good faith and with sincere efforts to reach an agreement to resolve the case.

         4. To save the parties from the need to invest resources in form of experts and other additional necessary discovery if the case does not settle, the parties stipulate to stay all proceedings in this case pending the completion of mediation in this case.

         5. The applicable discovery deadlines are as follows:

Amend pleadings/Add Parties: Closed
Initial Experts: December 16, 2019
Interim Status Report: December 16, 2019
Rebuttal Expert Designations: January 15, 2020
Discovery Cutoff: February 14, 2020
Dispositive Motions: March 13, ...

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