Schwartzer v. American Family Mutual Insurance Co.

Filing 58

ORDER Granting 56 Stipulation for Extension of Time (First Request) to File Joint Pretrial Order. Signed by Judge Andrew P. Gordon on 3/9/17. (Copies have been distributed pursuant to the NEF - MR)

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SAO
ROBERT VANNAH, ESQ.
NEVADA BAR NO. 002503
MARK L. JACKSON
NEVADA BAR NO. 010905
VANNAH & VANNAH
400 South Seventh St., Suite 400
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LENARD E. SCHWARTZER, in his capacity as
the Bankruptcy Trustee for the Bankruptcy Estate
of Alisson Santos,

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Plaintiff,
vs.
AMERICAN FAMILY MUTUAL INSURANCE
COMPANY, a corporation; and DOES I through
V; and, ROE CORPORATIONS VI through X,
inclusive,

JOINT STIPULATION AND ORDER TO
EXTEND TIME TO SUBMIT JOINT
PRETRIAL ORDER
(First Request)

Defendants.

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CASE NO.: 2:15-cv-01115-APG-PAL

IT

IS

HEREBY

STIPULATED

AND

AGREED,

by

Plaintiff,

LENARD

E.

SCHWARTZER and Defendant AMERICAN FAMILY MUTUAL INSURANCE COMPANY, by

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and through their undersigned counsel, that the following extension be made to the pretrial order

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schedule in this matter. If granted, this will be the first extension to the pretrial order schedule.
Counsel for Plaintiff and Defendant have been unable to meet to review the proposed
exhibits before submitting a pretrial order, as requested by the Honorable Judge Gordon, and now

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VANNAH & VANNAH

400 South Fourth Street 6th Floor • Las Vegas, Nevada 89101
Telephone [phone]
Facsimile [phone]

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request an extension of time to do so. Counsel for both Parties have exchanged exhibits and page-

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line designations for proposed depositions, and are in the process of finalizing stipulations to

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exhibits. Counsel have been unable to conduct the meet and confer as required as Counsel for

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Plaintiff has been conducting depositions and mediations all week, and counsel for Defendant has

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been ill, creating a situation where neither party has been able to meet with the other. Additionally,

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counsel for Plaintiff will be out of town from January 26, 2017, until January 30, 2017, on preexisting business, creating an insurmountable obstacle to convening a physical meeting of both

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counsel before the deadline on January 27, 2017. Counsel for both parties now stipulate and agree
to the following:
1.

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Counsel for Plaintiff and Defendant shall have up to and including February 3,

complies with Local Rules 16-3 and 16-4 and this Court’s December 28, 2016

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Order.

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/s/ MARK L. JACKSON

/S/ TROY A. CLARK

MARK L. JACKSON, ESQ.
Nevada Bar No.: 010905
VANNAH & VANNAH
400 S. Seventh Street, Suite 400
Las Vegas, Nevada 89101
Counsel for Plaintiff

PAUL A. ACKER, ESQ.
Nevada Bar No.: 3670
TROY A. CLARK, ESQ.
Nevada Bar No.: 11361
BREMER WHYTE BROWN & O’MEARA,
LLP
1160 N. Town Center Dr., Suite 250
Las Vegas, Nevada 89144
Counsel for Defendant

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VANNAH & VANNAH

2017, to conduct a meaningful meet and confer and submit a joint pretrial order that

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400 South Fourth Street 6th Floor • Las Vegas, Nevada 89101
Telephone [phone]
Facsimile [phone]

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ORDER

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IT IS HEREBY ORDERED, ADJUDGED, AND DECREED:

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1. Counsel for Plaintiff and Defendant shall have up to and including February 3, 2017, to

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conduct a meaningful meet and confer and submit a joint pretrial order that complies

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with Local Rules 16-3 and 16-4 and this Court’s December 28, 2016 Order.

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9th
March
IT IS SO ORDERED this _____ day of ___________, 2017.
By: __________________________________
U.S. DISTRICT COURT JUDGE

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Respectfully submitted:
/s/ MARK L. JACKSON

January 25, 2017

MARK L. JACKSON, ESQ.
Nevada Bar No.: 010905
VANNAH & VANNAH
400 S. Seventh Street, Suite 400
Las Vegas, Nevada 89101
Counsel for Plaintiff

/S/ TROY A. CLARK
PAUL A. ACKER, ESQ.
Nevada Bar No.: 3670
TROY A. CLARK, ESQ.
Nevada Bar No.: 11361
BREMER WHYTE BROWN & O’MEARA,
LLP
1160 N. Town Center Dr., Suite 250
Las Vegas, Nevada 89144
Counsel for Defendant

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VANNAH & VANNAH

400 South Fourth Street 6th Floor • Las Vegas, Nevada 89101
Telephone [phone]
Facsimile [phone]

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