Freud v. American States Insurance Company et al

Filing 23

ORDER Granting 22 Stipulation for Extension of Time re 12 MOTION to Remand to State Court .( Replies due by 1/16/2017.) Signed by Judge Jennifer A. Dorsey on 1/3/17. (Copies have been distributed pursuant to the NEF - ADR)

II
ANDREW C. GREEN, ESQ.
Nevada Bar No. 9399
KOELLER NEBEKER CARLSON
& HALUCK, LLP
400 S. 4t.': Street, Suite 600
Las Vegas, NV 89101
Phone: [phone]
Fax: [phone]
Attorneys for Defendants,
AMERICAN STATES INSURANCE COMPANY and
SAFECO INSURANCE COMPANY OF INDIANA

2
3
4
5

6

7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9

MARCIA FREUD, an Individual,

) CASE NO.: 2:16-cv-02623-JAD-VCF
)

10

Plaintiff,

)
)
vs.
)
)
AMERICAN STATES INSURANCE
)
COMPANY d/b/a SAFECO INSURANCE, )
an Indiana corporation; GUILLERMO
)
URRUTIA, an individual; BEATRIS
)
URRUTIA, an individual; DOES I through X, )
)
inclusive and ROE CORPORATIONS I
through X, inclusive,
)

11

12
13
14
15

STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
PLAINTIFF TO FILE ITS REPLY IN
SUPPORT OF MARCIA FREUD'S
MOTION TO REMAND AND MOTION
FOR ATTORNEY'S FEES

[ECF No. 22]

)

16

Defendants.

)

~~~~~~~~~~~~~~·>

17
18

COME NOW, Plaintiff, MARCIA FREUD (hereinafter "Plaintiff'), by and throuth

19

her attorney, the law firm of BREEDEN & ASSOCIATES, PLLC, and Defendants,

20

AMERICAN STATES INSURANCE COMP ANY (hereinafter "American States") and

21

SAFECO INSURANCE COMPANY OF INDIANA (hereinafter "Safeco") erroneously

22

named as AMERICAN STA TES INSURANCE COMPANY d/b/a SAFECO, and hereby

23

agree to an extension of time for Plaintiff to file her Reply in support of her Motion to Remand

24

I and

Motion for Attorney's Fees (hereinafter "Motion") (Court Document #12). The

25

Stipulation is intended to be submitted in compliance with LR IA 6-1. The underlying Motion

26

was filed December 12, 2016, and Plaintiffs Reply in support of that Motion is understood to

27

originally be due on this date, January 3, 2017. This is the first request to extend the deadline

28

for Plaintiff to file a Reply in support of her Motion. Presently, no hearing has been scheduled
Page 1 of2

II

442 156

for Plaintiffs Motion. The parties stipulate to extend the time for Plaintiff to file her Reply in

2 support of her motion to remand until January l 6, 2017.

3

To the extent necessary, the parties stipulate good cause appears to be presented to

4

permit the extension agreed-upon herein. In particular, the Stipulation is submitted on this date

5

upon learning of a medical emergency for counsel for Plaintiff requiring counsel for Plaintiff

6 ' to unexpectedly depart his o.ffice without ability to return unti I January 9, 2017, at the earl iest.
7

Dated this r 0 day of January, 2017.

Dated this 3•c• day of January, 2017.

8

BREEDEN & ASSOCIATES, PLLC

KOELLER NEBEKE
HALUCK, L .

9

10
II
12

13

By:

~~

.. ·,/-1_ ___..
_

· ·-·T(;yy~

By:

~c,r ADAM J. BREEDEN, ESQ.

A REW C. GREEN, ESQ.
Nevada Bar No. 9399
400 S. 41h Street, Suite 600
Las Vegas, NY 89101
Attorneys for Defendants,
AMERICAN STA TES
INSURANCE COMPANY and
SAFECO INSURANCE
COMPANY OF INDfANA

Nevada Bar No. 8768
1404 S. Jones Boulevard
Las Vegas, NV 89146
Attorney for Plaintiff,
MARCIA FREUD

14

15

16
I7
18
19

ORDER

ITGood cause appearing, IT IS HEREBY ORDERED that the time for1 to file her
IS HEREBY ORDERED that Plaintiff will have until January 16, 2017
plaintiff to file any reply in support of her motion to remand and for attorney's fees
Reply inNo. 12] is EXTENDEDRemand and 16, 2017. Attorney's Fees.
[ECF support of her Motion to to January Motion for
3rd
DATED this _ _ day of January, 2017.

20
21

UNITED STATES MAGISTRATE JUDGE
________________________________

Jennifer A. Dorsey
United States District Judge

22
23

24
25

26
27
28
Page 2 of2

442156