Filed: Oct. 31, 2018
Latest Update: Oct. 31, 2018
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (First Request) PEGGY A. LEEN , Magistrate Judge . Plaintiff Keoni Paul Kuloloia ("Plaintiff"), Defendants Ohio Security Insurance Company, Liberty Mutual Group, Inc. dba Liberty Mutual Insurance Company dba Liberty Mutual, Liberty Mutual Auto and Home Services, LLC, and Liberty Mutual Insurance Company dba Liberty Mutual Insurance Co., (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and re
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (First Request) PEGGY A. LEEN , Magistrate Judge . Plaintiff Keoni Paul Kuloloia ("Plaintiff"), Defendants Ohio Security Insurance Company, Liberty Mutual Group, Inc. dba Liberty Mutual Insurance Company dba Liberty Mutual, Liberty Mutual Auto and Home Services, LLC, and Liberty Mutual Insurance Company dba Liberty Mutual Insurance Co., (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and req..
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(First Request)
PEGGY A. LEEN, Magistrate Judge.
Plaintiff Keoni Paul Kuloloia ("Plaintiff"), Defendants Ohio Security Insurance Company, Liberty Mutual Group, Inc. dba Liberty Mutual Insurance Company dba Liberty Mutual, Liberty Mutual Auto and Home Services, LLC, and Liberty Mutual Insurance Company dba Liberty Mutual Insurance Co., (collectively "Defendants"), by and through their respective counsel of record, hereby stipulate and request that the Court extend certain discovery deadlines by approximately 90 days. This is the parties' first request to extend any discovery deadlines in this matter.
Pursuant to Local Rule 26-4, the parties state as follows:
I. DISCOVERY COMPLETED TO DATE
• The parties conducted the Fed. R. Civ. P. 26(f) conference.
• The parties have exchanged initial and supplemental disclosures of documents and lists of witnesses.
• Defendants propounded requests for production of documents, requests for admissions and interrogatories on Plaintiffs. Plaintiffs provided responses, and Defendants have requested that Plaintiff supplement those responses.
• The parties have disclosed expert witnesses and rebuttal expert witnesses.
II. DISCOVERY TO BE COMPLETED
• Plaintiff's written discovery to Defendants
• Deposition of Plaintiff
• Depositions of employees of Ohio Security Insurance Company
• Depositions of additional non-party fact witnesses.
• Depositions of expert witnesses.
The above list is made without prejudice to any party's ability to conduct additional discovery consistent with the Federal Rules of Civil Procedure.
III. REASONS WHY THE DEADLINES CANNOT BE COMPLETED WITHIN THE CURRENT SCHEDULE
The additional discovery time requested is to provide the parties with additional time to complete deposition discovery in this matter, including the depositions of the parties' disclosed experts. The parties anticipate taking approximately 10 combined depositions and due to upcoming trials, depositions in other matters, holiday periods, and related travel, the parties are requesting additional time to coordinate dates that are mutually convenient for the witnesses and counsel. The parties have begun discussing scheduling of these depositions and expect that an additional 90 days will provide sufficient time to complete the discovery remaining in this case, including all of the anticipated depositions. The parties agree that this request is not made for the purpose of delay, but to ensure a just adjudication of the case on the merits, and that none of them will be prejudiced by the requested extension.
IV. PROPOSED SCHEDULE
WHEREFORE, the parties respectfully request that this Court extend discovery deadlines as follows:
EVENT CURRENT PROPOSED DEADLINE
DEADLINE
Discovery Cut-off Date October 29, 2018 January 29, 2019
Dispositive Motions November 28, 2018 February 28, 2019
Pre-Trial Order The Joint Pre-Trial The Joint Pre-Trial Order shall
Order shall be filed no be filed no later than 30 days
later than 30 days after after the date set for filing
the date set for filing dispositive motions which in
dispositive motions this matter would be
which shall be March 28, 2019
December 28, 2018. If dispositive motions are
If dispositive motions timely filed, the date for filing
are timely filed, the date the Pre-Trial Order would be
for filing the Pre-Trial suspended.
Order shall be
suspended.
ORDER
IT IS SO ORDERED.
