AIG Specialty Insurance Company v. Liberty Mutual Insurance Company

Filing 82

ORDER Granting 76 Stipulation for Extension of Time Extending Time for Briefing re 74 Motion to Stay (First Request). Responses due by 11/28/2017. Replies due by 12/5/2017. Signed by Magistrate Judge Nancy J. Koppe on 11/28/2017. (Copies have been distributed pursuant to the NEF - MR)

Case 2:17-cv-01260-APG-NJK Document 76 Filed 11/27/17 Page 1 of 2

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Dominica C. Anderson (SBN 2988)
Daniel B. Heidtke (SBN 12975)
DUANE MORRIS LLP
100 N. City Parkway, Suite 1560
Las Vegas, NV 89106
Telephone: [phone]
Facsimile: 702.974.1058
Email: [e-mail]
[e-mail]

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Attorneys for Plaintiffs Liberty Mutual Fire Insurance Company

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
AIG SPECIALTY INSURANCE COMPANY
F/K/A CHARTIS SPECIALTY INSURANCE
COMPANY AND ALSO AMERICAN
INTERNATIONAL SPECIALTY LINES
INSURANCE COMPANY, an Illinois
Corporation;
Plaintiffs,

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STIPULATION AND ORDER
EXTENDING TIME FOR BRIEFING ON
PLAINTIFF’S MOTION TO STAY
DISCOVERY [ECF NO. 74]
(FIRST REQUEST)

vs.

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Case No.: 2:17-cv-01260-APG-NJK

LIBERTY MUTUAL FIRE INSURANCE
COMPANY, a Massachusetts Corporation; and
DOES 1 through 100, inclusive,

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Defendants.

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Plaintiff, AIG SPECIALTY INSURANCE COMPANY F/K/A CHARTIS SPECIALTY

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INSURANCE COMPANY AND ALSO AMERICAN INTERNATIONAL SPECIALTY LINES

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INSURANCE COMPANY (“Plaintiff”), and Defendant, LIBERTY MUTUAL FIRE INSURANCE

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COMPANY (“Defendant” and collectively, with Plaintiff the “Parties”), by and through their

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respective counsel of record, and pursuant to Local Rules 6-1(a) and 6-2, and Federal Rule of Civil

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Procedure Rule 6, hereby stipulate and agree as follows:

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WHEREAS, on October 25, 2017, the Parties filed a joint discovery plan on October 25, 2017
(ECF No. 71);

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WHEREAS, on October 25, 2017, this Court denied the Parties’ discovery plan and ordered

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Plaintiff to file, within 14 days of the order, a motion to stay discovery addressing the pertinent

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standards (ECF No. 72);
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STIPULATION AND ORDER EXTENDING TIME FOR BRIEFING ON MOTION TO STAY

Case 2:17-cv-01260-APG-NJK Document 76 Filed 11/27/17 Page 2 of 2

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WHEREAS, on November 9, 2017, Plaintiff filed a Motion to Stay Discovery (ECF No. 74);

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WHEREAS, Defendant’s Opposition to Plaintiff’s Motion to Stay Discovery, if any, is

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currently due November 27, 2017;
WHEREAS, Plaintiff’s Reply in Support of its Motion to Stay Discovery, if any, is due

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December 4, 2017;

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WHEREAS, Plaintiff and Defendant have been in discussion concerning a possible limited

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stipulation as to a stay of discovery in this matter. Consequently, an additional one (1) day extension

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would allow the Parties to continue these meaningful discussions which may relieve this Court of the

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burden of having to consider additional briefing; and
WHEREAS, Fed.R.Civ.P. 6(b) requires the Court to approve an extension of time, and

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therefore the Parties collectively request the Court approve the stipulation, as set forth below:

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a.

This is the Parties’ first stipulation for an enlargement of time;

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b.

The Parties stipulate and agree that the deadline for Defendant to file a Response to

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Plaintiff’s Motion to Stay shall be extended to November 28, 2017 and Plaintiff’s deadline to file a

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Reply in Support shall be extended to December 5, 2017; and

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c.

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IT IS SO STIPULATED.

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This stipulation is not made for purposes of delay.

DUANE MORRIS LLP

HEROLD & SAGER

By:

By:

/s/ Daniel B. Heidtke _____ __
Dominica C. Anderson (SBN 2988)
Daniel B. Heidtke (SBN 12975)

/s/ _ Joshua A. Zlotlow
_
Andrew D. Herold (SBN 7378)
Joshua A. Zlotlow (SBN 11333)
Attorneys for Plaintiff AIG Specialty Insurance
Attorneys for Defendant Liberty Mutual Fire Co. f/k/a Chartis Specialty Insurance Co. and
Insurance Company
also American International Specialty Lines
Insurance Co.
Dated: November 28
IT IS SO ORDERED this _____ day of _____________, 2017.

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U.S. DISTRICT MAGISTRATE JUDGE
United States Magistrate Judge
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STIPULATION AND ORDER EXTENDING TIME FOR BRIEFING ON MOTION TO STAY