Grogan v. State Farm Mutual Automobile Insurance Company

Filing 17

ORDER Granting 16 Stipulation to Extend Discovery Deadlines. Discovery due by 6/13/2018. Motions due by 7/13/2018. Proposed Joint Pretrial Order due by 8/13/2018. Signed by Magistrate Judge Cam Ferenbach on 2/13/2018. (Copies have been distributed pursuant to the NEF - ADR)

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MARK G. HENNESS, ESQ.
Nevada Bar No. 5842
[e-mail]
JACOB S. SMITH, ESQ.
Nevada Bar No. 10231
[e-mail]
HENNSS & HAIGHT
8972 Spanish Ridge Avenue
Las Vegas, Nevada 89148
[phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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PAMELA GROGAN, individually,
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Case No.: 2:17-cv-01044-APG-VCF
Plaintiffs,
vs.

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STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, an entity licensed
to do business in Nevada; DOES I through X;
and ROE CORPORATIONS, XI through XX,
inclusive,

STIPULATION AND ORDER TO
EXTEND DISOVERY DEADLINES
(First Request)

Defendants.

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COMES NOW, Plaintiff, PAMELA GROGAN, by and through her counsel of record,

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MARK G. HENNESS, ESQ. and JACOB S. SMITH, ESQ. of the law firm of HENNESS &

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HAIGHT and Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,

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by and through its counsel of record, BENJAMIN J. CARMAN, ESQ. of the law firm of RANALLI
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ZANIEL FOWLER & MORAN, and submit the following stipulation and order to extend discovery
deadlines pursuant to LR 26-4 as follows:
1. Summary of Discovery Completed
All parties have provided initial witness lists and documents pursuant to FRCP 26 and

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supplements thereto.

Plaintiff has executed authorizations served by Defendant.
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Plaintiff is

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presently working to schedule the depositions of State Farm Adjuster, Kim Korich, as well as the

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30(b)(6) witness(es) of State Farm. The parties are working to schedule the deposition of Plaintiff.

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2. Discovery Remaining
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The depositions of Plaintiff and Plaintiff’s treating doctors must be completed. Written
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discovery may be propounded by both parties. Depositions of non-party witnesses and the parties'

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expert witnesses (once disclosed) need to be taken.

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3. Reason Why Discovery Was Not Completed
Discovery in this matter is currently scheduled to close on April 13, 2018. Additional time

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is required to work through scheduling issues so that discovery may be completed. The parties have
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required additional time in order to coordinate the depositions of the Defendant’s employees and

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corporate representatives. This is the parties' first request for an extension of discovery deadlines in

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this matter; therefore, the parties have agreed to an extension of the discovery deadlines to enable

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them to complete the remaining discovery.

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4. Proposed Schedule for Completing Discovery
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Accordingly, the parties respectfully request that this Court enter an order setting the
following discovery plan and scheduling order dates:

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Event

Former Deadline

New Deadline

Discovery Deadline

04/13/18

06/13/18

Motions to Amend Pleadings and Add Parties

01/12/18

03/12/18

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Initial Expert Designations

02/12/18

04/12/18

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Rebuttal Expert Designations

03/14/18

05/14/18

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Dispositive Motions

05/14/18

07/13/18

Joint Pre-Trial Order

06/13/18

08/13/18

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If dispositive motions are filed, the deadline for filing the joint pretrial order will be
suspended until 30 days after decision on the dispositive motions or further court order.
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Counsel further states that the requested extension of the discovery deadline is not intended
for purposes of delay, but rather for the purposes set forth hereinabove.
Dated this 12th day of February, 2018.

Dated this 12th day of February, 2018.

HENNESS & HAIGHT

RANALLI ZANIEL FOWLER & MORAN,
LLC

_/s/ JACOB S. SMITH, ESQ.____________
MARK G. HENNESS, ESQ.
Nevada Bar No. 5842
JACOB S. SMITH, ESQ.
Nevada Bar No. 10231
8972 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Attorney for Plaintiff

___/s/ BENJAMIN J. CARMAN, ESQ._____
GEORGE M. RANALLI, ESQ.
Nevada Bar No. 5748
BENJAMIN J. CARMAN, ESQ.
Nevada Bar No. 12565
2400 West Horizon Ridge Parkway
Henderson, Nevada 89052
Attorneys for Defendant

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ORDER
13th
IT IS SO ORDERED this ____ day of February, 2018.

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____________________________________
UNITED STATES MAGISTRATE JUDGE

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Respectfully submitted by:

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HENNESS & HAIGHT

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____/S/ JACOB S. SMITH, ESQ.__________
MARK G. HENNESS, ESQ.
Nevada Bar No. 5842
JACOB S. SMITH, ESQ.
Nevada Bar No. 10231
8972 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Attorney for Plaintiff

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