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Apple v. CSAA General Insurance Company, 2:19-cv-01093-RFB-CWH. (2019)

Court: District Court, D. Nevada Number: infdco20190716d22 Visitors: 6
Filed: Jul. 15, 2019
Latest Update: Jul. 15, 2019
Summary: STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS THE SECOND AND THIRD CASES OF ACTION IN THE PLAINTIFF'S. COMPLAINT, OR IN THE ALTERNATIVE, TO SEVER/BIFURCATE AND TO STAY CLAIMS FOR BAD FAITH (FIRST REQUEST) RICHARD F. BOULWARE, II , District Judge . Pursuant to LR IA 6-1 and LR 26-4, Plaintiff Ruth Apple ("Plaintiff") and Defendants CSAA General Insurance Company dba AAA Insurance and CSAA Insurance Exchange dba AAA Insurance (collectively referre
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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS THE SECOND AND THIRD CASES OF ACTION IN THE PLAINTIFF'S. COMPLAINT, OR IN THE ALTERNATIVE, TO SEVER/BIFURCATE AND TO STAY CLAIMS FOR BAD FAITH

(FIRST REQUEST)

Pursuant to LR IA 6-1 and LR 26-4, Plaintiff Ruth Apple ("Plaintiff") and Defendants CSAA General Insurance Company dba AAA Insurance and CSAA Insurance Exchange dba AAA Insurance (collectively referred to as "Defendants"), by and through their attorneys of record, hereby stipulate and agree to extend the time for Plaintiff to respond to Defendants' Motion to Dismiss the Second and Third Causes of Action in Plaintiff's Complaint, or in the Alternative, to Sever/Bifurcate and to Stay Claims (ECF No. 10) from the current deadline of July 15, 2019, up to and including July 29, 2019. Additional time is being requested because Plaintiff and Plaintiff's counsel were not placed on the court's service list, had not been served with the Motion, and were unaware of the Motion until May 10, 2019. The Motion was served upon prior counsel Mainor Wirth Injury Lawyers. This is the parties' first request to extend these deadlines to respond.

This requested extension of time is sought in good faith and not for the purpose of causing undue delay.

IT IS SO STIPULATED.

Dated this 12th day of June, 2019. REMPFER MOTT LUNDY, PLLC McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH, LLP /s/Joseph N. Mott /s/ Philip A. John Joseph N. Mott Michael R. Merritt Nevada Bar No. 12455 Nevada Bar No. 5720 Scott E. Lundy Philip A. John Nevada Bar No. 14235 Nevada Bar No. 10627 Attorneys for Plaintiff Attorneys for Defendants Ruth Apple CSAA General Insurance Company and CSAA Insurance Exchange

ORDER

IT IS SO ORDERED.

Source:  Leagle

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