Kingham v. State Farm Mutual Automobile Insurance Company

Filing 44

ORDER Granting 43 Stipulation for Extension of Time (First Request). Proposed Joint Pretrial Order due by 11/30/2017. Signed by Magistrate Judge George Foley, Jr on 10/30/17. (Copies have been distributed pursuant to the NEF - MR)

1 ROBERT FREEMAN, ESQ.
Nevada Bar No. 003062
2 E-Mail: [e-mail]
PAMELA L. MCGAHA, ESQ.
3
Nevada Bar No. 008181
Email: [e-mail]
4
CHERYL A. GRAMES, ESQ.
5 Nevada Bar No. 012752
E-Mail: [e-mail]
6 LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
7 Las Vegas, Nevada 89118
8 PH: [phone]
FAX: [phone]
9 Attorneys for Defendant

STATE FARM MUTUAL AUTOMOBILE

10 INSURANCE COMPANY
11

UNITED STATES DISTRICT COURT

12

DISTRICT OF NEVADA

13

***

14
15

KATHRYN KINGHAM,
Plaintiff,

16
17

vs.

CASE NO.: 2:15-cv-01555-APG-GWF
STIPULATION TO EXTEND TIME TO
FILE JOINT PRE-TRIAL ORDER
(FIRST REQUEST)

18 STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, duly authorized
19 to conduct business in the State of
Nevada; DOES 1 through 10, inclusive,
20 and ROE CORPORATIONS 1 through 10
inclusive,
21
Defendants.
22
23

IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES, Plaintiff Kathryn

24 Kingham and Defendant State Farm Mutual Automobile Insurance Company (
25 individually, “Plaintiff” and “Defendant,” respectively, and collectively, the “Parties”), by
26 and through their respective counsel, and in accordance with LR IA 6-1 and Fed. R. Civ.
27 Proc. 6(b)(1)(A), that the due date for the Parties to file the Joint Pre-Trial Order be

LEWIS

28 extended thirty (30) days from the current deadline of October 30, 2017, up to and

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4812-1351-9698.1

1 including November 30, 2017.
2

The Parties do not seek this request for an extension of time for any improper

3 purpose or to delay these proceedings unnecessarily. Counsel for the Parties have met
4 and conferred, and have agreed that extending the Pre-Trial Order deadline by thirty days
5 best serves the interests of the Parties following the Court’s granting in part and denying
6 in part State Farm’s Motion for Partial Summary Judgment (ECF No. 42), and in light of
7 their respective schedules.
8

WHEREFORE, the Parties respectfully request that this Court extend the time for

9 the Parties to file their Joint Pre-Trial Order by thirty (30) days from the current deadline
10 of October 30, 2017 up to and including November 30, 2017.
11 DATED this 26th day of October 2017.

DATED this 26th day of October 2017.

12 LEWIS BRISBOIS BISGAARD & SMITH LLP

BRENSKE & ANDREEVSKI

13
14
15
16
17
18

/s/ Cheryl A. Grames

/s/ William R. Brenske

ROBERT W. FREEMAN, ESQ.
Nevada Bar No. 003062
PAMELA L. MCGAHA, ESQ.
Nevada Bar No. 008181
CHERYL A. GRAMES, ESQ.
Nevada Bar No. 012752
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, NV 89118

WILLIAM R. BRENSKE, ESQ.
Nevada Bar No. 001806
JENNIFER R. ANDREEVSKI, ESQ.
Nevada Bar No. 009095
RYAN D. KRAMETBAUER, ESQ.
Nevada Bar No. 012800
3800 Howard Hughes Parkway, Ste. 500
Las Vegas, NV 89169

19 Attorneys for Defendant STATE FARM

Attorneys for Plaintiff KATHRYN
KINGHAM

20 MUTUAL AUTOMOBILE INSURANCE
COMPANY
21

ORDER

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23

IT IS SO ORDERED.

24

October 30
DATED:_____________________, 2017.

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26
___________________________
HON. ANDREW P. GORDON
GEORGE W. FOLEY, JR.
UNITED STATES MAGISTRATE JUDGE

27

LEWIS

28

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4812-1351-9698.1

2