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Shaffer v. Aetna Life Insurance Company, 2:18-cv-02357-JAD-VCF. (2019)

Court: District Court, D. Nevada Number: infdco20190731d97 Visitors: 10
Filed: Jul. 29, 2019
Latest Update: Jul. 29, 2019
Summary: STIPULATION AND ORDER TO EXTEND DEADLINE (SECOND REQUEST) CAM FERENBACH , Magistrate Judge . IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the discovery schedule as set forth in the Scheduling Order dated May 13, 2019 [docket 19], be amended as follows: I. Discovery Completed Defendant provided the proposed Administrative Record (AR) to Plaintiff for review on March 26, 2019. Counsel for the parties met and
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STIPULATION AND ORDER TO EXTEND DEADLINE

(SECOND REQUEST)

IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the discovery schedule as set forth in the Scheduling Order dated May 13, 2019 [docket 19], be amended as follows:

I. Discovery Completed

Defendant provided the proposed Administrative Record (AR) to Plaintiff for review on March 26, 2019. Counsel for the parties met and conferred by phone on April 17, 2019 regarding potential discovery and content of the AR. Plaintiff served discovery requests upon Defendant and Defendant's responses have been provided.

II. Discovery Remaining and Reason for Request for Extension

The parties now have a dispute as to a few of Defendant's discovery responses which they believe will be resolved shortly without the need for Court intervention. The current deadline to file discovery briefs in this case is 7/29/19. The parties have agreed among themselves to extend this sole deadline by approximately two weeks, to August 15, 2019. All other deadlines will remain unchanged.

III. Proposed Discovery Schedule Change

Plaintiff SHAFFER and Defendant AETNA agree and stipulate to the following proposed deadline extension:

Description: Current Deadline: Proposed: Discovery Briefs 07/29/19 08/15/19

We, the undersigned, represent to the Court that this request for extension is made in good faith and not for purposes of delay.

WHEREFORE, the parties jointly request that this Court adopt the proposed scheduling deadlines as indicated above.

DATED: July 29, 2019 BURKE, WILLIAMS & SORENSEN, LLP By: /s/Michael B. Bernacchi MICHAEL B. BERNACCHI mbernacchi@bwslaw.com 444 South Flower Street, Suite 2400 Los Angeles, CA 90071-2953 Michael R. Brooks, Esq. mbrooks@klnevada.com KOLESAR & LEATHAM 400 South Rampart Blvd., Suite 400 Las Vegas, NV 89145 Attorneys for Defendant AETNA DATED: July 29, 2019 LAW OFFICE OF JULIE A. MERSCH By: /s/Julie A. Mersch JULIE A. MERSCH jam@merschlaw.com Nevada Bar No.: 004695 1100 E. Bridger Ave. Las Vegas, NV 89101 Attorney for Plaintiff SHAFFER

IT IS SO ORDERED.

Source:  Leagle

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