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
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 c..
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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 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.