Bisbee v. CSAA General Insurance Company

Filing 25

ORDER Granting 24 Stipulation for Extension of Time re Discovery Deadlines (First Request). Signed by Magistrate Judge Peggy A. Leen on 4/28/17. (Copies have been distributed pursuant to the NEF - MR)

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GEORGE M. RANALLI, ESQ.
Nevada Bar No. 5748
BENJAMIN J. CARMAN, ESQ.
Nevada Bar No. 12565
RANALLI ZANIEL FOWLER & MORAN, LLC
2400 W. Horizon Ridge Parkway
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant
CSAA General Insurance Company

HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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MARJORIE BISBEE

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Plaintiff,

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v.

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CSAA GENERAL INSURANCE COMPANY;
DOES I through X; and ROE
CORPORATIONS I through X,
inclusive

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2:16-cv-01500-JAD-PAL

STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES
(First Request)

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Defendant
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IT IS HEREBY STIPULATED AND AGREED by Plaintiff, MARJORIE

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BISBEE, and Defendant, CSAA GENERAL INSURANCE COMPANY to Extend

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Discovery Deadlines by 60 days.

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A. STATEMENT SPECIFING THE DISCOVERY COMPLETED:
The following discovery has been completed by the parties:

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1.

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Defendant’s

Initial

Disclosure,

pursuant

to

FRCP

Initial

Disclosure,

pursuant

to

FRCP

26(f);

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2.

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Plaintiff’s
26(f);

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3.

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Defendant’s First Set of Requests for Admissions to
Plaintiff;

HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

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Defendant’s First Set of Interrogatories to Plaintiff;

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RANALLI ZANIEL FOWLER & MORAN, LLC

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5.

Defendant’s First Set of Request for Production of

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Documents to Plaintiff;
B. A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE

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COMPLETED:

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1.

Depositions

of

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Plaintiff’s

medical

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rendered to Plaintiff since the date of this accident;

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2.

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the

Person

Most

providers

Knowledgeable

relevant

to

from

treatment

Depositions of Plaintiff’s claim handling expert who
is located out of state;

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3.

Deposition of Plaintiff;

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4.

Deposition of Defense Experts.

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A.

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WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER:

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THE REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED

The

parties

anticipate

taking

the

depositions

of

the

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plaintiff, representatives from CSAA General and experts on the

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first available dates.

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to

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three

week

trial,

Defense counsel is about to begin a two
starting

May

3,

2017

and

will

be

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unavailable

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Plaintiff’s counsel has a trial beginning at the end of May that

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is expected to last approximately four weeks.

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The

to

schedule

parties

are

additional
addition

sufficiently

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not

discovery.

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HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

but

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2400 W. HORIZON RIDGE PARKWAY

deadlines,

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RANALLI ZANIEL FOWLER & MORAN, LLC

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or

requesting

sixty
to

request
The

days

conclude

the

only

to

parties
will

a

the

depositions.

reopen
deadline

the

expert

matter.

of

instead

coordinate

believe

accommodate

discovery

that

to

that

conduct

a

modest

both
remains

parties
in

this

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D.

A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:
Old Deadline

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New Deadline

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Discovery Cut off:

05/10/2017

07/10/2017

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Expert Disclosure:

03/10/2017

CLOSED

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Rebuttal of Experts:

04/10/2017

CLOSED

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Dispositive Motions:

06/10/2017

08/09/2017

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F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY
DELAYING DISCOVERY OR THE TRIAL OF THIS MATTER.
DATED this 26th day of April, 2017.
RANALLI ZANIEL FOWLER & MORAN,
LLC

SEEGMILLER & ASSOCIATES

_/s/ Benjamin J. Carman______
GEORGE M. RANALLI, ESQ.
Nevada Bar No. 5748
BENJAMIN J. CARMAN, ESQ.
Nevada Bar No. 12565
2400 W. Horizon Ridge Parkway
Henderson, Nevada 89052
Attorneys for Defendant

_/s/ Clark Seegmiller_________
CLARK SEEGMILLER, ESQ.
Nevada Bar No. 3873
10655 Park Run Drive, Suite
250
Las Vegas, NV 89144
Attorney for Plaintiff,
Marjorie Bisbee

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HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

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ORDER

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IT IS SO ORDERED:

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April 28, 2017
Dated: _______________
_____________________________
UNITED STATES DISTRICT COURT
MAGISTRATE JUDGE