L.A. Pacific Center, Inc. v. Charter Oak Fire Insurance Company

Filing 26

ORDER Granting 23 Stipulation to Extend Time. Discovery due by 9/8/2015. Motions due by 10/8/2015. Proposed Joint Pretrial Order due by 11/9/2015. Signed by Magistrate Judge Cam Ferenbach on 9/22/2015. (Copies have been distributed pursuant to the NEF - DC)

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Amy M. Samberg, Nevada Bar No. 10212
Justin S. Hepworth, Nevada Bar No. 10080
SNELL & V/ILMER r.r.p.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email : j hepworth@swlaw. com
Attorneys for Defendant
THE CHARTER OAK FIRE
INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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DISTRICT OF'NEVADA

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L.A. PACIFIC CENTER, INC., a Nevada

CASE NO. : 2: 1 4-cv-01977 -GMN-VCF

corporation,
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Plaintiffs,

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STIPULATION AND ORDER TO
EXTEND CERTAIN DISCOVERY
DEADLINES

VS.

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THE CHARTER OAK FIRE INSURANCE
COMPANY, a Connecticut corporation,

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** First Request **

Defendant.

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Pursuant to Local Rule 26-4, Plaintiff

L.A. Pacific Center, Inc. ("Plaintiff') and Defendant

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The Charter Oak Fire Insurance Company ("Charter Oak") hereby submit the following

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Stipulation and Order to Extend Time to Complete Discovery. While Plaintiff reserves the right

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to file a motion to extend all remaining discovery deadlines, the purpose of this request is to

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extend the current discovery deadline by 30 days solely to facilitate the deposition of Plaintiff

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person most knowledgeable which was properly noticed for August 3I,2015, but needs to be

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rescheduled to accommodate scheduling issues. The parties do not agree that any other deadlines

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(including the cunent discovery deadline for any other discovery) need to be extended.

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A.

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The parties exchanged their initial disclosures as required by Local Rule 26-1(a)(2).

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Discovery Completed

Charter Oak served its expert disclosure on June

9,2015. Charler Oak issued subpoenas to non-

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parties American Leak Detection, Arroyo Engineering Consuitants and James G. Johnson,

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PhD/Professional Loss Services. Charter Oak served its First Supplemental Disclosure Statement

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on August 17,2015, which included the documents received to date in response to

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aforementioned subpoenas. Charter Oak also served written discovery on Plaintiff on luly 27,

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2015. Responses to such written discovery are due on August 31, 2015. Charter Oak also

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noticed the deposition of Plaintiff s person most knowledgeable for August 31,2015. Charter

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Oak filed its Motion for Summary Judgment on August 13,2015.

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B.

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The deposition of Plaintiffs person most knowledgeable needs to be

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Discovery Remaining
completed.

still due from Arroyo Engineering Consultants and James

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its Motion for Summary Judgment which is currently pending before the Court. Plaintiff reserves

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the right to file a motion to extend all remaining discovery deadlines to conduct additional

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discovery.

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due. Charter Oak does not believe that any additional discovery is necessary and has already filed

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Johnson, PhD/Professional Loss Services. Responses to written discovery to Plaintiff are still

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Responses to the subpoenas are

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The deposition of Plaintiffls person most knowledgeable which is currently set for August

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31, 2015, needs to be rescheduled to a time convenient to counsel and the parties. There is

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insufficient time under the existing scheduling order to reschedule this deposition before the

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current discovery deadline of September 8,2015. The parties request an additional 30 days to

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complete the deposition of Plaintifls person most knowledge to accommodate scheduling issues

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including an upcoming trial in a separate matter being tried by Charter Oak's counsel.

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D.

Reasons Why Discovery Not Completed

Proposed Schedule for Completion of Discovery

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Old Deadline

New Deadline

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Amend Pleadings & Adding Parties

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Passed

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Disclosure of Experts and Reports

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Passed

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Disclosure of Rebuttal Experts and Reports

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Passed

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Interim Status Reports

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Filed

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Close of Discovery (except the depositions
of Plaintiffls person most knowledgeable)

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Close of Discovery (deposition of Plaintiffls
person most knowledgeable)

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Dispositive Motions

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0/8/1 s

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Joint Pre-Trial Order

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WHEREFORE, the parties respectfully request that the Court extend the discovery
deadlines as outlined above.

Respectfully submitted this 28th day of August, 2015.

SNELL & WILMER

I.I.p.

LAW OFFICES OF STEVEN J. PARSONS

By /s/ Joseoh N. Mott
By : /s/ Justin S. Hepworth
Steven J. Parsons
Amy M. Samberg
Nevada Bar No. 363
Nevada Bar No. I02I2
Joseph N. Mott
Justin S. Hepworth
Nevada Bar No. 12455
Nevada Bar No. 10080
7201W. Lake Mead Blvd., Suite
3883 Howard Hughes Parkway, Suite 1100

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Las Vegas, NV 89128-8354

Las Vegas, NV 89169
Attorneys for Defendant Charter
Fire Insurance Company

At t or ney s for P I aintiff

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ORDER
IT IS SO ORDERED.

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22nd

DATED

this

September
day of August, 2015

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U. S. MAGISTRATE JUDGE

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