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Adair v. State Farm Mutual Automobile Insurance Company, 2:17-cv-00421-RFB-CWH. (2018)

Court: District Court, D. Nevada Number: infdco20180601f06 Visitors: 5
Filed: May 30, 2018
Latest Update: May 30, 2018
Summary: *SUBMITTED IN COMPLIANCE WITH LR 26-1(e)* CARL W. HOFFMAN , Magistrate Judge . STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST) 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 ninety days. A. STATEMENT SPECIFING THE DISCOVERY COMPLETED: The following discovery has been completed by the parties: 1. Plaintiff's List of Witnesses and Documents Pr
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*SUBMITTED IN COMPLIANCE WITH LR 26-1(e)*

STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)

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 ninety days.

A. STATEMENT SPECIFING THE DISCOVERY COMPLETED:

The following discovery has been completed by the parties:

1. Plaintiff's List of Witnesses and Documents Produced Pursuant to FRCP 26 was produced on October 4, 2017; 2. Defendant's Disclosure of Witnesses and Exhibits Pursuant to FRCP 26(f) was produced on October 9, 2017; 3. Plaintiff's First Supplemental List of Witnesses and Documents Produced Pursuant to FRCP 26; 4. Plaintiff's Second Supplemental List of Witnesses and Documents Produced Pursuant to FRCP 26; 5. Defendant's First Supplemental Disclosure of Witnesses and Exhibits Pursuant to FRCP 26(f); 6. Defendant's First Set of Interrogatories to Plaintiff 7. Defendant's First Set of Requests for Production of Documents to Plaintiff; 8. Defendant's First Set of Requests for Admissions to Plaintiff; 9. Plaintiff's First Set of Interrogatories to Defendant; 10. Plaintiff's First Set of Requests for Production of Documents to Defendant 11. Plaintiff's First Set of Requests for Admissions to Defendant; 12. Plaintiff has noticed the deposition of Nikki Clary; 13. Plaintiff has noticed the deposition of Sandra Gowdy; 14. Deposition of Plaintiff; 15. Defendant's Responses to Plaintiff's Requests for Admissions; 16. Plaintiff's Responses to Defendant's Request for Admissions; 17. Defendant's Responses to Plaintiff's Interrogatories; 18. Plaintiff's Responses to Defendant's First Set of Interrogatories; 19. Defendant's Responses to Plaintiff's Requests for Production of Documents; 20. Plaintiff's Responses to Defendant's First Set of Request for Production of Documents; 21. Plaintiff has noticed the deposition of the Person Knowledgeable of State Farm; 22. Defendant's Designation of Expert Witnesses; 23. Plaintiff's Designation of Expert Witnesses and 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. Disclosures of Plaintiff and Defendant's rebuttal experts; 3. Depositions of Plaintiff and Defendant's experts; 4. Obtaining Plaintiff's medical records;

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 and have noticed depositions and served discovery, including their designation of experts in this matter. Both parties are aware of the numerous depositions they would like to take and the conflicting schedules of not only counsel, but the deponents. In addition, the parties recently exchanged expert disclosures and both parties believe they will need more time to prepare their experts as well as retain additional rebuttal experts. The parties are requesting a ninety day extension to complete all remaining discovery and depositions. This extension will allow the parties to accommodate counsels' schedule as well as the remaining deponents. Further, this will allow the parties to obtain the necessary experts needed.

D. A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:

Old Deadline New Deadline Discovery Cut off: 07/16/2018 10/15/2018 Amending the Pleadings 04/17/2018 CLOSED & Adding Parties: Expert Disclosure: 05/17/2018 CLOSED Rebuttal of Experts: 06/15/2018 09/17/2018 Interim Status Report: 05/17/2018 08/16/2018 Dispositive Motions: 08/15/2018 11/14/2018 PretrialOrder: 09/14/2018 12/14/2018

F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY DELAYING DISCOVERY OR THE TRIAL OF THIS MATTER.

ORDER

IT IS SO ORDERED.

Source:  Leagle

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