Universal North America Insurance Company v. Colosi et al

Filing 45

ORDER Granting 43 Stipulation to Extend Time re 30 MOTION for Summary Judgment , 39 MOTION for Partial Summary Judgment and 40 MOTION to Strike. See Order for deadlines. Signed by Judge Jennifer A. Dorsey on 9/26/17. (Copies have been distributed pursuant to the NEF - ADR)

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Case 2:17-cv-00113-JAD-GWF Document 43 Filed 09/26/17 Page 1 of 2 1 ROBERT W. FREEMAN, ESQ. Nevada Bar No. 03062 2 E-Mail: Robert.Freeman@lewisbrisbois.com PRISCILLA L. O’BRIANT, ESQ. 3 Nevada Bar No. 10171 E-Mail: Priscilla.Obriant@lewisbrisbois.com 4 LEWIS BRISBOIS BISGAARD & SMITH LLP 6385 S. Rainbow Blvd., Suite 600 5 Las Vegas, NV 89118 TEL.: 702-893-3383 6 FAX: 702-893-3789 Attorneys for Plaintiff 7 Universal North America Insurance Company 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 UNIVERSAL NORTH AMERICA 11 INSURANCE COMPANY, a Texas corporation, 12 Plaintiff, 13 vs. 14 Wendy Colosi, an individual; Victor Colosi, an 15 individual; Nicholas Colosi, an individual; Marilyn Kennedy, an individual; DOES 1-20 16 and ROE CORPORATIONS 1 - 20, inclusive, 17 Defendants. 2:17-cv-00113 STIPULATION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF TO RESPOND TO THE COLOSI DEFENDANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT AND COUNTERMOTION FOR (1) PARTIAL SUMMARY JUDGMENT CONCERNING DUTY TO DEFEND AND (2) TO STAY MATTER PENDING CONCLUSION OF UNDERLYING CASE {DKT 38 AND 39] AND THE COLOSI DEFENDANTS’ MOTION TO STRIKE/OBJECTION TO ANY REFERENCE TO JUVENILE COURT PROCEEDINGS [DKT 40] (FIRST REQUEST) 18 19 CASE NO.: Pursuant to LR 6-1, Plaintiff Universal North America Insurance Company (“Universal”) 20 and Defendant Marilyn Kennedy (“Kennedy”), by and through their respective counsel of record, 21 respectfully submit the following stipulation requesting a ten (10) day extension for Universal to 22 file a Reply to The Colosi Defendants’ Response to Motion for Summary Judgment [Dkt 38) 23 (“Response”); The Colosi Defendants’ Countermotion for (1) Partial Summary Judgment 24 Concerning Duty to Defend and (2) to Stay Matter Pending Conclusion of Underlying Case [Dkt 25 39] (“Countermotion”}] and The Colosi Defendants’ Motion to Strike/Objection to Any Reference 26 to Juvenile Court Proceedings [Dkt 40] (“Motion”). Universal’s Motion for Summary Judgment 27 on All Claims [dkt. 30] was filed on August 15, 2017 and the Response, Countermotion and LEWIS 28 Motion were filed on September 15, 2017. Universal’s Reply to the Response [dkt 38] and Motion BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4834-4624-6992.1 Case 2:17-cv-00113-JAD-GWF Document 43 Filed 09/26/17 Page 2 of 2 1 [dkt 40] currently due on September 29 will now be due October 9, 2017. Universal’s Response 2 to the Countermotion [dkt 39] currently due October 6, 2017 will now be due October 16, 2017. 3 In support of this Stipulation, the parties state as follows: 4 A. Introduction 5 Universal insured Defendants Wendy, Victor and Nicholas Colosi (the “Colosi 6 Defendants”), who are also defendants in a personal injury action filed by Kennedy. Universal 7 filed this declaratory relief action seeking a declaration regarding its duties and obligations to the 8 Colosi Defendants with respect to the lawsuit against them filed by Kennedy. 9 10 B. Reason for Extension The parties believe that a ten (10) day extension of the deadline to respond to the above is 11 necessary and appropriate to provide sufficient time for Universal to adequately respond. 12 Universal’s counsel requested the extension since she was on vacation when the Response, Motion 13 and Countermotion were filed, which adversely interfered with Universal’s opportunity to 14 complete its Reply and Responses in a timely matter. Universal and the Colosi Defendants 15 believe that good cause is demonstrated and both agreed to a ten (10) day extension of the 16 deadline(s) to respond. 17 Dated this 26th day of September, 2017 Dated this 26th day of September, 2017 18 Attorneys for Defendants Wendy Colosi, Victor Colosi and Nicholas Colosi 19 Attorneys for Universal 20 /s/ James W. Whitmire James W. Whitmire, Esq. 21 Nevada Bar No. 6533 Santoro Whitmire 22 10100 W. Charleston Blvd., Ste. 250 Las Vegas, Nevada 89135 23 /s/ Priscilla L. O’Briant Priscilla O’Briant, Esq. Nevada Bar No. 10171 Lewis Brisbois Bisgaard & Smith 6385 S. Rainbow Blvd., Ste. 600 Las Vegas, Nevada 89118 24 IT IS SO ORDERED this ___ day of ___________, 2017. 26th day of September, 2017. 25 26 ______________________________________ UNITED STATES DISTRICT COURT / UNITED STATES DISTRICT JUDGE MAGISTRATE JUDGE 27 LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4834-4624-6992.1 2

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