Filed: Apr. 20, 2018
Latest Update: Apr. 20, 2018
Summary: AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (THIRD REQUEST) CAM FERENBACH , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED by Plaintiff, JONI LeGALLEY, and Defendant, CSAA GENERAL INSURANCE COMPANY a Foreign Entity aka AAA NEVADA INSURANCE COMPANY aka AAA INSURANCE, hereinafter CSAA GENERAL INSURANCE COMPANY to Extend Discovery Deadlines by sixty days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: 1. Plaintiff's initial disclosures pursuant to FRCP 26; 2. Defen
Summary: AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (THIRD REQUEST) CAM FERENBACH , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED by Plaintiff, JONI LeGALLEY, and Defendant, CSAA GENERAL INSURANCE COMPANY a Foreign Entity aka AAA NEVADA INSURANCE COMPANY aka AAA INSURANCE, hereinafter CSAA GENERAL INSURANCE COMPANY to Extend Discovery Deadlines by sixty days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: 1. Plaintiff's initial disclosures pursuant to FRCP 26; 2. Defend..
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AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(THIRD REQUEST)
CAM FERENBACH, Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED by Plaintiff, JONI LeGALLEY, and Defendant, CSAA GENERAL INSURANCE COMPANY a Foreign Entity aka AAA NEVADA INSURANCE COMPANY aka AAA INSURANCE, hereinafter CSAA GENERAL INSURANCE COMPANY to Extend Discovery Deadlines by sixty days.
A. STATEMENT SPECIFING THE DISCOVERY COMPLETED:
1. Plaintiff's initial disclosures pursuant to FRCP 26;
2. Defendant American Automobile Association of Northern California, Nevada & Utah disclosures pursuant to FRCP 26;
3. Defendant CSAA General Insurance Company a foreign entity disclosures pursuant to FRCP 26;
4. Plaintiff's Request for Production of Documents to American Automobile Association of Northern California, Nevada & Utah;
5. Defendant American Automobile Association of Northern California, Nevada & Utah Response to Plaintiff's Request for Production of Documents;
6. Defendant American Automobile Association of Northern California, Nevada & Utah First Supplemental Response to Plaintiff's Request for Production of Documents;
7. Plaintiff's Request for Production of Documents to CSAA General Insurance Company;
8. Defendant CSAA General Insurance Company Response to Plaintiff's Request for Production of Documents;
9. Plaintiff's first supplemental disclosures pursuant to FRCP 26;
10. Defendant CSAA General Insurance Company a foreign entity first supplemental disclosures pursuant to FRCP 26;
11. Defendant CSAA General Insurance Company a foreign entity second supplemental disclosures pursuant to FRCP 26;
12. Plaintiff's Responses to Defendant, CSAA's Request for Admissions;
13. Plaintiff's Responses to Defendant, CSAA's Interrogatories;
14. Plaintiff's Responses to Defendant, CSAA's Request for Production of Documents;
15. Plaintiff's Expert Witness Disclosures;
16. Defendant's Designation of Expert Witnesses and Documents;
17. Defendant's First Supplemental Designation of Expert Witnesses and Documents;
18. Defendant CSAA General Insurance Company a foreign entity third supplemental disclosures pursuant to FRCP 26;
19. Deposition of Joni LeGalley;
20. Deposition of Louis Mortillaro, PhD;
21. Deposition of Richard Cestkowski, D.O.;
22. Deposition of Ryan Grabow, M.D.;
23. Deposition of William Muir, M.D.;
24. Deposition of Brian Ogg;
25. Notice of Deposition of Brett Wolff;
26. Notice of Deposition of Person Most Knowledgeable of CSAA;
27. Notice of Deposition of Heather Howell;
B. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:
Plaintiff intends to take the deposition of at least two additional adjusters, as well as the deposition of the personal most knowledgeable of CSAA that is currently on calendar but being moved due to a calendar conflict with Defense counsel and CSAA. Defendant intends to depose Mr. Gellner. Both parties intend to take additional expert witness depositions. Further, after the depositions have been conducted, additional discovery may need to be completed.
C. REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER.
Both parties have been working diligently to complete discovery in a timely manner. However, parties have been having trouble getting dates that work with all parties and witnesses schedules.
Further, Plaintiff's counsel was in and out of state for a trial throughout February, March, and April. Scheduling witness depositions has proved challenging, but the remaining depositions have been put on calendar.
The parties believe that a sixty day extension will allow both parties to complete all remaining depositions.
D. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY:
The parties have agreed to the following modified deadlines:
Discovery Cut off: 04/19/2018 06/18/2018
Expert Disclosure: 11/20/2017 CLOSED
Rebuttal of Experts: 12/20/2018 05/18/2018
Interim Status Report: 11/20/2017 CLOSED
Dispositive Motions: 05/21/2018 07/18/2018
Pre Trial Order: 06/20/2018 08/17/2018
F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY DELAYING DISCOVERY OR THE TRIAL OF THIS MATTER.
If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order.
ORDER
IT IS SO ORDERED.
