Adair v. State Farm Mutual Automobile Insurance Company

Filing 21

ORDER granting 20 Stipulation to Extend Deadlines. Discovery due by 10/15/2018. Motions due by 11/14/2018. Proposed Joint Pretrial Order due by 12/14/2018. Signed by Magistrate Judge Carl W. Hoffman on 5/30/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-00421-RFB-CWH Document 20 Filed 05/29/18 Page 1 of 5

1
2
3
4
5
6

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
State Farm Mutual Automobile Insurance Company

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

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

7
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

8
9
10

ETHAN ALAN ADAIR (FKA ALAN
VEYTSMAN), individually

11
Plaintiff,

2:17-cv-00421-RFB-CWH

12
v.
13

15

STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,individually;
DOES I - X, and ROE
CORPORATIONS I - X,

16

*SUBMITTED IN COMPLIANCE
WITH LR 26-1(e)*

Defendant

14

17
18

STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(SECOND REQUEST)

19
20

Pursuant to Local Rules 6-1 and 26-4, the parties, by and

21

through their respective counsel of record, hereby stipulate to

22

and request that the Court extend the deadlines by ninety days.

23
24
25

Case 2:17-cv-00421-RFB-CWH Document 20 Filed 05/29/18 Page 2 of 5

1
2
3

A.

STATEMENT SPECIFING THE DISCOVERY COMPLETED:

The following discovery has been completed by the parties:
1.

Plaintiff’s List of Witnesses and Documents Produced
Pursuant to FRCP 26 was produced on October 4, 2017;

4

Defendant’s

Disclosure

of

6

Pursuant

FRCP

was

7

2017;

5

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

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

8

2.

3.

4.

produced

on

Exhibits

October

9,

Plaintiff’s First Supplemental List of Witnesses and

Plaintiff’s Second Supplemental List of Witnesses and
Documents Produced Pursuant to FRCP 26;

11
12

26(f)

and

Documents Produced Pursuant to FRCP 26;

9
10

to

Witnesses

5.

Defendant’s First Supplemental Disclosure of Witnesses
and Exhibits Pursuant to FRCP 26(f);

13
14

6.

Defendant’s First Set of Interrogatories to Plaintiff

15

7.

Defendant’s First Set of Requests for Production of
Documents to Plaintiff;

16
17

8.

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

18
19

9.

Plaintiff’s First Set of Interrogatories to Defendant;

20

10.

Plaintiff’s First Set of Requests for Production of
Documents to Defendant

21
22

11.

Defendant;

23
24
25

Plaintiff’s First Set of Requests for Admissions to

12.

Plaintiff has noticed the deposition of Nikki Clary;

Case 2:17-cv-00421-RFB-CWH Document 20 Filed 05/29/18 Page 3 of 5

1

13.

Plaintiff has noticed the deposition of Sandra Gowdy;

2

14.

Deposition of Plaintiff;

3

15.

Defendant’s

4
5

Responses

to

Responses

Plaintiff’s

to

Requests

for

Request

for

Admissions;
16.

6

Plaintiff’s

Defendant’s

Admissions;

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

2400 W. HORIZON RIDGE PARKWAY

17.

Defendant’s Responses to Plaintiff’s Interrogatories;

8
RANALLI ZANIEL FOWLER & MORAN, LLC

7

18.

Plaintiff’s

9
10

19.

Defendant’s

First

Set

of

Defendant’s

Responses

to

Plaintiff’s

Requests

for

Production of Documents;
20.

13
14

to

Interrogatories;

11
12

Responses

Plaintiff’s

Responses

to

Defendant’s

First

Set

of

Request for Production of Documents;
21.

15

Plaintiff has noticed the deposition of the Person
Knowledgeable of State Farm;

16

22.

Defendant’s Designation of Expert Witnesses;

17

23.

Plaintiff’s

18
19

Designation

of

Expert

Witnesses

and

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

20

COMPLETED:

21

1.

Depositions

of

22

Plaintiff’s

medical

23

rendered to Plaintiff since the date of this accident;

24
25

the

Person

Most

providers

Knowledgeable

relevant

to

from

treatment

Case 2:17-cv-00421-RFB-CWH Document 20 Filed 05/29/18 Page 4 of 5

1

2.

Disclosures

2

of

Plaintiff

and

Defendant’s

rebuttal

experts;

3

3.

Depositions of Plaintiff and Defendant’s experts;

4

4.

Obtaining Plaintiff’s medical records;

5

A.

6

WITHIN THE TIME LIMITS SET BY THE DISCOVERY ORDER:

7

THE REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED

Both

parties

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

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

8

matter

forward

9

discovery,

have
and

been

working

diligently

have
their

including

noticed

designation

to

depositions
of

move

and

experts

this

served
in

this

10

matter.

Both parties are aware of the numerous depositions they

11

would like to take and the conflicting schedules of not only

12

counsel, but the deponents.

13

exchanged expert disclosures and both parties believe they will

14

need

15

additional

16

ninety day extension to complete all remaining discovery and

17

depositions.

18

accommodate

counsels’

19

deponents.

Further, this will allow the parties to obtain the

20

necessary experts needed.

21

D.

more

time

to

rebuttal

24
25

their

experts.

This

extension

experts

The

parties

will

schedule

as

as

are

allow
well

well

retain

requesting

the
as

as

parties

the

a

to

remaining

A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:
Old Deadline

22
23

prepare

In addition, the parties recently

Discovery Cut off:

New Deadline

07/16/2018

10/15/2018

Case 2:17-cv-00421-RFB-CWH Document 20 Filed 05/29/18 Page 5 of 5

1

Amending the Pleadings
& Adding Parties:

04/17/2018

CLOSED

Expert Disclosure:

05/17/2018

CLOSED

Rebuttal of Experts:

06/15/2018

09/17/2018

Interim Status Report:

05/17/2018

08/16/2018

Dispositive Motions:

08/15/2018

11/14/2018

Pretrial Order:

09/14/2018

12/14/2018

2
3
4
5
6
7
F. SAID REQUEST IS NOT BEING MADE FOR PURPOSES OF UNDULY
8
HENDERSON, NEVADA 89052
TELEPHONE: [phone] FAX: [phone]

2400 W. HORIZON RIDGE PARKWAY

RANALLI ZANIEL FOWLER & MORAN, LLC

DELAYING DISCOVERY OR THE TRIAL OF THIS MATTER.
9
Dated: May 29, 2018

Dated: May 29, 2018

RANALLI ZANIEL FOWLER & MORAN,
LLC

THE POWELL LAW FIRM

/s/ Benjamin 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/ Paul Powell__________
PAUL D. POWELL, ESQ.
Nevada Bar No. 7488
MICHAEL A. KRISTOF, ESQ,
Nevada Bar No. 7780
4435 South Eastern Avenue
Las Vegas, Nevada 89119
Attorney for Plaintiff

10
11
12
13
14
15
16
17
ORDER

18
19
20
21
22
23
24
25

IT IS SO ORDERED:
May 30, 2018
Dated: _______________
______________________
UNITED STATES DISTRICT COURT
MAGISTRATE JUDGE