Doremus et al v. American Family Mutual Insurance Company

Filing 22

ORDER Granting [21Second Stipulation re Deadlines. Discovery due by 6/18/2018. Motions due by 7/16/2018. Proposed Joint Pretrial Order due by 8/15/2018. Signed by Magistrate Judge Cam Ferenbach on 3/13/2018. (Copies have been distributed pursuant to the NEF - SLD)

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Kevin C. Barrett, State Bar No. 8959
BARRETT | MATURA
8925 East Pima Center Parkway, Suite 100
Scottsdale, Arizona 85258
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Defendant
American Family Mutual Insurance Company

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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FRED DOREMUS, individually; and
LINDA DOREMUS, individually,

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Plaintiffs,

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Case No. 2:17-CV-01034-RFB-VCF

vs.
AMERICAN FAMILY MUTUAL
INSURANCE COMPANY, a foreign
entity; DOES I through X; and ROE
CORPORATIONS, XI through XX,
inclusive,

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STIPULATION AND ORDER FOR
EXTENSION OF REMAINING
DEADLINES
[SECOND REQUEST]

Defendants.

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Pursuant to Federal Rule of Civil Procedure 29(b) and Local Rules 6-1, 7-1, and LR

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26-4, the parties hereby submit the following Stipulation and Order for Extension of

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Remaining Deadlines (Second Request) to extend the discovery deadlines and all related

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case management deadlines, as set forth in the Court's Scheduling Order [Doc. 13] and

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Order granting Stipulation to Extend Discovery Deadline [Doc. 17], by approximately 90

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days.

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I.

STATUS OF DISCOVERY EFFORTS TO DATE

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The parties have conducted the following discovery to date:

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

Disclosure statements have been exchanged.

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

Defendant served Plaintiffs with Interrogatories and Requests for Production

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on September 19, 2017.


Plaintiffs have responded to Interrogatories and Requests for Production on
October 23, 2017.

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

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November, 2017.


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
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Defendant’s responses to Plaintiffs’ Interrogatories, Requests for Production,
and Requests for Admission will be filed on March 12, 2018.



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Plaintiffs issued Interrogatories, Requests for Production, and Requests for
Admission to Defendant on February 6, 2018.

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Some medical records have been produced by Plaintiffs’ medical providers,
but not all.

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Defendant issued subpoenas duces tecum to Plaintiffs’ medical providers in

Plaintiffs have taken the depositions of the claim handlers involved in this
matter and some 30(b)(6) representatives.

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Expert opinions have been exchanged.

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II. DISCOVERY REMAINING


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Pending subpoena responses from remaining medical providers to be
received by Defendant.

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

Deposition of Plaintiffs.

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Deposition of an additional 30(b)(6) Defendant representative.

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Expert depositions.

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Depositions of additional fact witnesses, as necessary.

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Additional subpoenas and written discovery, as necessary.

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III.

REASONS FOR REQUESTED EXTENSION

Pursuant to Local Rule 26-4, the parties submit that good cause exists for the
extension requested below for the following reasons:

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The parties have been diligent in conducting written discovery, issuing subpoenas

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to collect Plaintiffs’ relevant medical information, and beginning the deposition process.

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However, at this time, the parties have been unable to schedule all of the necessary

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depositions within the current deadlines. Additionally, without all of the relevant medical

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records collected, it would be premature for Defendant to depose Plaintiffs. The parties

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are working together to facilitate mutually acceptable dates for the remaining depositions.
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As such, good cause is present to extend the current case deadlines, as evidenced by

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the discovery efforts listed above. The parties have diligently worked together to move

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this case forward.

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IV.

CURRENT DATES AND REQUESTED EXTENSIONS

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The parties hereby request an extension of the remaining case deadlines as follows:

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1.

Discovery Cutoff Date:

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Current date: March 18, 2018

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Requested Extension:

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2.

June 18, 2018

Dispositive Motions:

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Current date: April 17, 2018

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Requested Extension:

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July 16, 2018

Pretrial Order:

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Current date: May 17, 2018

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Requested Extension:

August 15, 2018 (unless dispositive motions are

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filed, in which case the pretrial order shall be filed thirty days after the decision on

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the dispositive motions or further order from the Court).

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4.

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The parties have complied with the Scheduling Order and its deadlines thus far.

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This request is the parties’ second request to extend any discovery deadlines, and it is made

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in good faith.

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All other deadlines set forth in the Scheduling Order will remain the same.

For the reasons above, the parties submit that good cause exists to extend discovery,

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dispositive motions, and pretrial order, all in accordance with the accompanying Order.

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DATED: March 13, 2018

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HENNESS & HAIGHT

BARRETT | MATURA

By: /s/ Jacob Smith (w/ permission)
Jacob Smith
Attorneys for Plaintiffs
Fred & Linda Doremus

By: /s/ Kevin C. Barrett
Kevin C. Barrett
Attorneys for Defendant
American Family Mutual Ins. Co.

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ORDER
IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE
DATED: March 13, 2018

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CERTIFICATE OF SERVICE

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I hereby certify that on March 13, 2018, I electronically transmitted the foregoing
document to the Clerk’s Office using the CM/ECF system for filing and that a copy of
same was deposited for mailing, first class mail, postage prepaid, to the following:

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Mark G. Henness, Esq.
Jacob S. Smith, Esq.
HENNESS & HAIGHT
8972 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Attorneys for Plaintiffs
/s/ Carolyn Harrington

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