Filed: Jan. 18, 2018
Latest Update: Jan. 18, 2018
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND 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 ninety days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: 1. Plaintiff's initial disclosures pursuant to FRCP 26; 2. Defendant
Summary: STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND 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 ninety days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: 1. Plaintiff's initial disclosures pursuant to FRCP 26; 2. Defendant A..
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND 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 ninety 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; (to be disclosed this week);
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;
B. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:
Defendant, CSAA will scheduling the depositions of the Plaintiff, along with the depositions of Plaintiff's treating providers and potential witnesses. Plaintiff will be scheduling the deposition of Defendant's Rule 30(b)(6) witness and adjuster on the file. Plaintiff intends to take the depositions of Defendant's expert(s).
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 all discovery in a timely manner. However, parties have been having trouble getting dates from doctors within a reasonable time frame for depositions. This was despite efforts beyond two months to obtain dates that would accommodate the schedules of the doctors and counsel, and was not the result of any last minute scheduling efforts.
Further, Plaintiff's counsel has been in and out of state for a trial and will be continuing to travel in and out for state for trial throughout February, March, and April.
The parties believe that a ninety day extension will allow both parties to complete all remaining discovery and resolve all the issues they have been having with scheduling conflicts as well.
D. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY:
The parties have agreed to the following modified deadlines:
Discovery Cut off: 01/19/2018 04/19/2018
Expert Disclosure: 11/20/2017 CLOSED
Rebuttal of Experts: 12/20/2018 CLOSED
Interim Status Report: 11/20/2017 CLOSED
Dispositive Motions: 02/19/2018 03/21/2018 5-21-2018
Pre Trial Order: 03/21/2018 04/20/2018 6-20-2018
F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY DELAYING DISCOVERY OR THE TRIAL OF THIS MATTER.
ORDER
IT IS SO ORDERED.
