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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1 2 3 4 5 6 7 MARK G. HENNESS, ESQ. Nevada Bar No. 5842 JACOB S. SMITH, ESQ. Nevada Bar No. 10231 HENNSS & HAIGHT 8972 Spanish Ridge Avenue Las Vegas, Nevada 89148 (702) 862-8200 Attorneys for Plaintiff 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 PAMELA GROGAN, individually, 11 12 Case No.: 2:17-cv-01044-APG-VCF Plaintiffs, vs. 13 14 15 16 17 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. 18 19 COMES NOW, Plaintiff, PAMELA GROGAN, by and through her counsel of record, 20 MARK G. HENNESS, ESQ. and JACOB S. SMITH, ESQ. of the law firm of HENNESS & 21 HAIGHT and Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, 22 by and through its counsel of record, BENJAMIN J. CARMAN, ESQ. of the law firm of RANALLI 23 24 25 26 27 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 28 supplements thereto. Plaintiff has executed authorizations served by Defendant. -1- Plaintiff is 1 presently working to schedule the depositions of State Farm Adjuster, Kim Korich, as well as the 2 30(b)(6) witness(es) of State Farm. The parties are working to schedule the deposition of Plaintiff. 3 2. Discovery Remaining 4 The depositions of Plaintiff and Plaintiff’s treating doctors must be completed. Written 5 6 discovery may be propounded by both parties. Depositions of non-party witnesses and the parties' 7 expert witnesses (once disclosed) need to be taken. 8 9 3. Reason Why Discovery Was Not Completed Discovery in this matter is currently scheduled to close on April 13, 2018. Additional time 10 is required to work through scheduling issues so that discovery may be completed. The parties have 11 12 required additional time in order to coordinate the depositions of the Defendant’s employees and 13 corporate representatives. This is the parties' first request for an extension of discovery deadlines in 14 this matter; therefore, the parties have agreed to an extension of the discovery deadlines to enable 15 them to complete the remaining discovery. 16 4. Proposed Schedule for Completing Discovery 17 18 19 Accordingly, the parties respectfully request that this Court enter an order setting the following discovery plan and scheduling order dates: 20 21 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 24 Initial Expert Designations 02/12/18 04/12/18 25 Rebuttal Expert Designations 03/14/18 05/14/18 26 Dispositive Motions 05/14/18 07/13/18 Joint Pre-Trial Order 06/13/18 08/13/18 22 23 27 28 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. -2- 1 2 3 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 4 5 6 7 8 9 10 11 12 13 14 15 ORDER 13th IT IS SO ORDERED this ____ day of February, 2018. 16 17 ____________________________________ UNITED STATES MAGISTRATE JUDGE 18 19 Respectfully submitted by: 20 HENNESS & HAIGHT 21 22 23 24 25 26 27 ____/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 28 -3-

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