Keenan v. State Farm Mutual Auto Insurance Company, 2:17-cv-01999-RFB-VCF. (2017)
Court: District Court, D. Nevada
Number: infdco20171207d36
Visitors: 21
Filed: Dec. 06, 2017
Latest Update: Dec. 06, 2017
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) SUBMITTED IN COMPLIANCE WITH LR 26-1(e) CAM FERENBACH , Magistrate Judge . Pursuant to Local Rules 6-1 and 26-4, the parties, by and through their respective counsel of record, hereby stipulate to and request that the Court extend the deadlines by sixty days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: The following discovery has been completed by the parties: 1. Defendant's Initial Disclosure, pursuant to FRCP 26
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) SUBMITTED IN COMPLIANCE WITH LR 26-1(e) CAM FERENBACH , Magistrate Judge . Pursuant to Local Rules 6-1 and 26-4, the parties, by and through their respective counsel of record, hereby stipulate to and request that the Court extend the deadlines by sixty days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: The following discovery has been completed by the parties: 1. Defendant's Initial Disclosure, pursuant to FRCP 26(..
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)
SUBMITTED IN COMPLIANCE WITH LR 26-1(e)
CAM FERENBACH, Magistrate Judge.
Pursuant to Local Rules 6-1 and 26-4, the parties, by and through their respective counsel of record, hereby stipulate to and request that the Court extend the deadlines by sixty days.
A. STATEMENT SPECIFING THE DISCOVERY COMPLETED:
The following discovery has been completed by the parties:
1. Defendant's Initial Disclosure, pursuant to FRCP 26(f);
2. Plaintiff's Initial Disclosure, pursuant to FRCP 26(f);
3. Defendant's First Supplemental Initial Disclosure, pursuant to FRCP 26(f);
4. Defendant's First Set of Request for Admissions to Plaintiff, Charles Keenan;
5. Defendant's First Set of Request for Admissions to Plaintiff, Tammy Keenan;
6. Plaintiff's Requests for Admissions to Defendant;
7. Plaintiff, Charles Keenan, Responses to Defendant's Requests for Admissions;
8. Plaintiff, Tammy Keenan, Responses to Defendant's Requests for Admissions;
9. Defendant's Responses to Plaintiff's Requests for Admissions;
10. Plaintiff's Interrogatories to Defendant;
11. Defendant's Interrogatories to Plaintiff, Charles Keenan;
12. Defendant's Interrogatories to Plaintiff, Tammy Keenan;
13. Plaintiff, Charles Keenan, Responses to Defendant's Interrogatories;
14. Plaintiff, Tammy Keenan, Responses to Defendant's Interrogatories;
15. Defendant's Responses to Plaintiff's Interrogatories;
16. Defendant's Request for Production of Documents to Plaintiff, Charles Keenan;
17. Defendant's Request for Production of Documents to Plaintiff, Tammy Keenan;
18. Plaintiff's Request for Production of Documents to Defendant;
19. Plaintiff, Charles Keenan, Responses to Defendant's Request for Production of Documents;
20. Plaintiff, Tammy Keenan, Responses to Defendant's Request for Production of Documents;
21. Defendant's Responses to Plaintiff's Request for Production of Documents;
B. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:
1. Depositions of the Person Most Knowledgeable from Plaintiff's medical providers relevant to treatment rendered to Plaintiff since the date of this accident;
2. Deposition of Plaintiff;
3. Deposition of Defendant's representatives;
4. Disclosures of Plaintiff and Defendant's experts;
5. Depositions of Plaintiff and Defendant's experts;
6. Independent Medical Examination of Plaintiff, Tammy Keenan;
A. THE REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER:
Both parties have been working diligently to move this matter forward. At this time both parties are requesting are requesting an additional sixty days to obtain experts. Both parties believe that the additional time will allow the parties to retain their experts during the holiday time, obtain the remaining depositions and perform an Independent Medical Examination of Plaintiff, Tammy Keenan. Further, the parties believe that this will better position the parties for a potential settlement conference and early resolution of this dispute.
D. A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:
Old Deadline New Deadline
Discovery Cut off: 02/19/18 04/20/2018
Amending Pleadings 11/21/17 CLOSED
& Adding Parties:
Expert Disclosure: 12/21/17 02/19/2018
Rebuttal of Experts: 01/17/2018 03/21/2018
Interim Status Report: 12/21/2017 02/19/2018
Dispositive Motions: 03/20/2018 05/21/2018
F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY DELAYIN DISCOVERY OR THE TRIAL OF THIS MATTER.
ORDER
IT IS SO ORDERED.
Source: Leagle
