Styles et al v. State Farm Mutual Automobile Insurance Company

Filing 29

ORDER granting 28 Stipulation; Discovery due by 6/25/2018. Motions due by 7/25/2018. Proposed Joint Pretrial Order due by 8/24/2018. Signed by Magistrate Judge Peggy A. Leen on 12/18/2017. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01197-RFB-PAL Document 28 Filed 12/08/17 Page 1 of 4

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RYAN L. DENNETT, ESQ.
Nevada Bar No. 005617
[e-mail]
JENNIFER INSLEY MICHERI, ESQ.
Nevada Bar No. 010089
[e-mail]
DENNETT WINSPEAR, LLP
3301 N. Buffalo Drive, Suite 195
Las Vegas, Nevada 89129
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant, State Farm
Mutual Automobile Insurance Company

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JUDITH ANN STYLES,
LEIGH ANN STYLES,
Case No: 2:17-CV-01197-RFB-PAL

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Plaintiffs,

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vs.

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STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY; ROES I thru V,
and DOES I through X, inclusive,

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STIPULATION FOR EXTENSION OF
TIME TO COMPLETE DISCOVERY
(FIRST REQUEST)

Defendants.

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COME NOW, the parties above named, by and through counsel, and move the

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Honorable Magistrate Judge for an Order continuing Discovery and submit the instant Stipulation

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in accordance with LR 6-1 and LR 26-4. The parties have conferred and agree that an extension

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of remaining discovery dates (those remaining dates not expired prior to the stay imposed by the

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Court) is both necessary and warranted following the Plaintiffs’ retention of new counsel after its

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former counsel, George W. Carter, Esq. and co-counsel, David Lee Phillips, Esq. withdrew and

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various discovery matters were not completed by Plaintiffs due to the issues previously

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addressed in open Court on November 2, 2016 and December 4, 2017.

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No previous requests or extensions for time in which to complete discovery in this matter

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have been requested.

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Case 2:17-cv-01197-RFB-PAL Document 28 Filed 12/08/17 Page 2 of 4

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An extension of time for discovery is necessary and good cause exists for the extension

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pursuant to Local Rule 26-4. Pursuant to that Rule, the parties submit the following:

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(a)

DISCOVERY THAT HAS BEEN COMPLETED

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Counsel for the respective parties participated in a discovery planning conference

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pursuant to Fed.R.Civ.P. 26(f). Lists of witnesses and document productions were thereafter

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exchanged by and between the parties. A Proposed Discovery Plan was filed on June 22, 2017

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and Ordered by the Court on June 26, 2017.

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Written discovery to the Plaintiffs has been served and answered, Plaintiffs’ depositions

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have been previously scheduled, but those depositions were stayed by the Court Order.

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Defendant has disclosed its expert.

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(b)

DISCOVERY THAT REMAINS TO BE COMPLETED

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The parties will be conducting additional factual and expert discovery, including the

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depositions of Plaintiffs and of the parties affiliated with Defendant State Farm involved in the

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handling of Plaintiff's claim. Plaintiffs and Defendant have agreed that Plaintiffs may disclose

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their rebuttal expert as the time to do so had not yet expired when the Stay went into effect and

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Defendant shall have the right to supplement its expert disclosure, if necessary.

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(c)

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REASONS DISCOVERY WILL NOT BE COMPLETED WITHIN THE TIME LIMITS SET
BY THE DISCOVERY PLAN
Due to the withdrawal of Plaintiffs’ former counsel and retention of new counsel, it has

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become necessary to extend the discovery for a period of six months.
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Case 2:17-cv-01197-RFB-PAL Document 28 Filed 12/08/17 Page 3 of 4

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(d)

PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY:
The parties hereby stipulate and request that discovery dates in this matter be continued

for ninety (180) days.
Current Dates:

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Proposed Dates:

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Discovery Cut-Off Date:

Dec.25, 2017

June 25, 2018 1

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Fed.R.Civ.P. 26(a)(2) Disclosures
(Experts):

Oct. 26, 2017

Expired

Rebuttal Experts:

November 26, 2017

January 26, 2017

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Deadlines to file Dispositive Motions: January 24, 2018

July 25, 2018

Pretrial Order Due Date:

February 23, 2018

August 24, 2018

Interim Status Report (LR 26-3):

October 26, 2018

May 28, 2018 2

Any request to extend the dates set forth in this Discovery Plan and Scheduling Order
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shall be submitted to the Court not later than 21 days before the expiration of the subject
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deadline sought to be extended.
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INITIAL DISCLOSURES AND DISCOVERY
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Initial Disclosures have previously been disclosed by both parties. No objections to the
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Objections to Initial Disclosures were filed. (Fed. R. Civ. P. 26(f)(3)(A)).
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The parties anticipate conducting written discovery and depositions on all issues allowed
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under the Federal Rules of Civil Procedure. (Fed. R. Civ. P. 26(f)(3)(B)).
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The parties hereto will submit a stipulated protective order and confidentiality agreement
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to be filed with the Court prior to the disclosure of Defendant's materials regarding Plaintiff's
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contractual and extra-contractual claims against Defendant. (Fed. R. Civ. P. 26(f)(3)(D)).
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There are currently no issues which parties are aware of regarding discovery of
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electronically stored information or claims of privilege/protection of trial preparation materials.
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(Fed. R. Civ. P. 26(f)(3)(C-D)).
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180 Days = Saturday, June 23, 2018 = Monday, June 26, 2018.
60 days before close of discovery = Saturday, June 23, 2018 = Monday, June 26, 2018

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Case 2:17-cv-01197-RFB-PAL Document 28 Filed 12/08/17 Page 4 of 4

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There are currently no changes which should be made in the limitations on discovery

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imposed by the Federal or Local Rules of practice and no additional orders that this Court should

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issue at this time. (Fed. R. Civ. P. 26(f)(3)(E-F)).

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DATED:

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LAW OFFICES OF STEPHEN M. DIXON

DENNETT WINSPEAR, LLP

By
/s/ Stephen M. Dixon
Stephen M. Dixon, Esq.
Nevada Bar No. 10025
10181 W. Park Run, #110
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiffs,
Judith Anny Styles & Leigh Ann Styles

By
/s/ Ryan L. Dennett
Ryan L. Dennett, Esq.
Nevada Bar No. 5617
Jennifer Insley Micheri, Esq.
Nevada Bar No. 010089
3301 N. Buffalo Drive, Suite 195
Las Vegas, Nevada 89129
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant, State Farm
Mutual Automobile Insurance Company

December 8, 2017

DATED:

December 8, 2017

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ORDER

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IT IS SO ORDERED.

December 18, 2017
DATED: ______________________
________________________________________
UNITED STATES MAGISTRATE JUDGE

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