Cox Communications Las Vegas, Inc. v. Zurich American Insurance Company

Filing 40

ORDER AMENDING SCHEDULING ORDER re 39 Stipulation to extend Discovery Deadlines. Discovery due by 12/29/2014. Dispositive Motions due by 1/28/2015. Proposed Joint Pretrial Order due by 1/28/2015. Signed by Magistrate Judge Nancy J. Koppe on 7/30/2014. (Copies have been distributed pursuant to the NEF - DKJ)

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Howard J. Russell, Esq.
Nevada Bar No. 8879
[e-mail]
WEINBERG, WHEELER, HUDGINS,
GUNN & DIAL, LLC
6385 S. Rainbow Blvd., Suite 400
Las Vegas, Nevada 89118
Telephone:
[phone]
Facsimile:
[phone]
Attorney for Plaintiff
Cox Communications Las Vegas, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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COX COMMUNICATIONS LAS VEGAS, INC.,

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Case No.:

2:13-CV-1483-GMN-NJK

Plaintiff,
STIPULATION AND PROPOSED
ORDER TO EXTEND DISCOVERY
DEADLINES

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v.

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ZURICH AMERICAN INSURANCE
COMPANY,

(THIRD REQUEST)

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Defendant.
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The parties hereby jointly stipulate to extend the discovery deadlines in this matter,

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pursuant to Local Rule 26-4, respectfully showing as follows. The within Request is filed more

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than 21 days prior to the present discovery cut-off of :

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1.

Discovery completed to date:

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a.

Initial disclosures of witnesses and documents by all parties;

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b.

Supplement disclosures of witnesses and documents by all parties;

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c.

Interrogatories and Requests to Produce to Plaintiff by Defendant, and responses

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thereto;
d.

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Interrogatories and Requests to Produce to Defendant by Plaintiff, and responses
thereto;

e.

Notices of depositions served on custodian of records, fact witnesses and FRCP
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30(b)(6) witnesses;

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f.

Supplemental Interrogatories and Requests for Production;

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g.

Requests for Admissions.

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2.

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Discovery remaining to be completed:
a.

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Completion of depositions of party representatives and fact witnesses

The reason discovery has not been completed:

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Both parties have filed motions for summary judgment, and each party believes this case

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can be resolved in its favor as a matter of law. However, the parties have continued with discovery

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efforts, and numerous depositions have been noticed. Due to the number of depositions, the travel

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schedule of counsel, and the potential that some depositions may be conducted outside of Nevada,

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scheduling the depositions may prove difficult. As such, the parties request additional time to

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complete these depositions.

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4.

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Proposed schedule for completing remaining discovery:
Discovery cut-off:
December 29, 2014
Last day to file dispositive motions:
January 28, 2015 (30 days after discovery cut-off)
Last day to file pre-trial order and FED. R. CIV. P. 26(a)(3) disclosures:

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January 28, 2015, or 30 days after decision on any dispositive motions filed

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after the close of discovery

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Dated: July 29, 2014.

Dated: July 29, 2014

/s/ Theodore J. Kurtz
Theodore J. Kurtz, Esq.
SELMAN BREITMAN LLP
3993 Howard Hughes Pkwy., Suite 200
Las Vegas, NV 89169-0961

/s/ Howard J. Russell
Howard J. Russell, Esq.
WEINBERG, WHEELER, HUDGINS
GUNN & DIAL, LLC
6385 S. Rainbow Blvd., Suite 400
Las Vegas, Nevada 89118

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Attorney for Defendant
Zurich American Insurance Company

Attorney for Plaintiff
Cox Communications Las Vegas, Inc.

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Page 2 of 3

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ORDER AMENDING SCHEDULING ORDER

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For good cause shown, and on the stipulation of the parties, the Scheduling Order in this

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matter is hereby amended consistent with the schedule agreed to by the parties in Paragraph 4

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above.

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IT IS SO ORDERED:

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DATED: July 30, 2014.

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_____________________________________
Hon. Nancy J. Koppe
United States Magistrate
________________________________
NANCY J. KOPPE
United States Magistrate Judge
Dated: ________________________, 2014

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