LV Diagnostics, LLC v. Hartford Financial Services Group, Inc. et al

Filing 29

ORDER granting 28 Stipulation re Discovery Deadlines. Discovery due by 6/28/2018. Motions due by 7/30/2018. Proposed Joint Pretrial Order due by 8/29/2018.FURTHER ORDERED that no further extensions will be granted. Signed by Magistrate Judge Peggy A. Leen on 4/6/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01371-JCM-PAL Document 28 Filed 04/04/18 Page 1 of 4

1
2
3
4
5
6
7
8

DARREN T. BRENNER, ESQ.
Nevada Bar No. 8386
JAMIE K. COMBS, ESQ.
Nevada Bar No. 13088
AKERMAN LLP
1635 Village Center Circle, Suite 200
Las Vegas, Nevada 89134
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Hartford Financial
Services Group, Inc., and Sentinel Insurance
Company, Ltd.

9

UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA

AKERMAN LLP

1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: [phone] – FAX: [phone]

11
12

LV DIAGNOSTICS, LLC, a Nevada limited
liability company,

13

Case No.: 2:17-cv-01371-JCM-PAL
STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES

Plaintiff,

14
15

(THIRD REQUEST)

v.
THE HARTFORD FINANCIAL SERVICES
GROUP, INC., a Connecticut corporation;
SENTINEL INSURANCE COMPANY, LTD., a
Connecticut corporation; DOES I through X,
inclusive; and ROE CORPORATIONS I through
X, inclusive,

16
17
18

Defendants.

19
20

Defendants Hartford Financial Services Group, Inc. (Hartford), and Sentinel Insurance

21

Company, Ltd. (Sentinel) (collectively Defendants), and plaintiff LV Diagnostics, LLC (Plaintiff),

22

respectfully submit the following stipulation requesting a thirty (30) day extension of the current

23

scheduling order deadlines.

24

I.

INTRODUCTION.

25

This case is a dispute arising out of an insurance policy covering the building and business

26

personal property at Plaintiff's location at 600 S. Martin Luther King Boulevard, in Las Vegas, NV.

27

Plaintiff allegedly suffered loss as a result of a break-in on April 8, 2015, and made a claim on its

28

insurance policy. Plaintiff filed a complaint in State Court on April 7, 2017, alleging breach of
1
44816693;1

Case 2:17-cv-01371-JCM-PAL Document 28 Filed 04/04/18 Page 2 of 4

1

contract, breach of the covenant of good faith and fair dealing, bad faith, and unfair trade practices.

2

On May 15, 2017, Defendants removed this matter to Federal Court. A discovery plan and

3

scheduling order was entered on July 14, 2017 [ECF Docket #17]. An order to extend discovery

4

deadlines was entered on November 14, 2017 [ECF Docket # 23]. A second order to extend

5

discovery deadlines was entered on January 17, 2018 [ECF Docket # 26].

6

II.

DISCOVERY STATUS.

7
8

On January 17, 2018, the court entered an order to extend discovery deadlines which
set the following deadlines:
Discovery Cut Off: Tuesday, May 29, 2018.

(b).

Motions to amend pleadings or add parties: No extension requested.

11

AKERMAN LLP

(a).

10

1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: [phone] – FAX: [phone]

9

(c).

Initial Expert Disclosures: Friday, March 30, 2018.

12

(d).

Rebuttal Expert Disclosures: Tuesday, May 1, 2018.

13

(e).

Interim Status Report: Friday, March 30, 2018.

14

(f).

Dispositive Motions: Friday, June 29, 2018.

15

(g).

Pretrial Order: Monday, July 30, 2018.

16

(h).

Extensions or Modifications of the Discovery Plan and Scheduling Order:

17
18

Monday, May 7, 2018.
A.

Discovery that has been completed.

19

1.

Defendants served their initial disclosures on October 10, 2017.

20

2.

Plaintiff served its initial disclosures on October 2, 2017. The certificate of

21

service indicates that they were mailed earlier, but they were not received.

22

After correspondence, they were submitted.

23

3.

24

Defendants served their first set of requests for production of documents and
first set of interrogatories to Plaintiff on October 10, 2017.

25

4.

26

Defendants served their first supplement to initial disclosures on October 10,
2017.

27

5.

Plaintiff served its supplemental disclosures on November 28, 2017.

28

6.

The deposition of Edgar Manukyan occurred on December 8, 2017.
2

44816693;1

Case 2:17-cv-01371-JCM-PAL Document 28 Filed 04/04/18 Page 3 of 4

1

7.

2

Plaintiff served its responses to defendant's first set of interrogatories on
January 31, 2018.

3

8.

4

Plaintiff served its responses to defendants first set of requests for production
of documents on February 23, 2018.

5

9.

6

Defendants served their second supplement to initial disclosures on March 12,
2018.

7

B.

Discovery that Remains.
Expert disclosures;

2.

Deposition of Expert Witnesses;

10

3.

Follow up on Written Discovery;

11

AKERMAN LLP

1.

9

1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: [phone] – FAX: [phone]

8

4.

Plaintiff's continued deposition (and follow up discovery on any new issues

12

that arise at the deposition)

13

The parties reserve the right to take additional discovery during the time frames outlined

14

below should the need arise.

15

III.

REASON WHY EXTENSION IS REQUIRED.

16

The parties recently held a meet and confer regarding the Plaintiffs' responses to written

17

discovery, and are requesting an additional thirty (30) days of discovery in order for plaintiff to

18

continue to gather necessary documents and to supplement their responses, and for Defendant to

19

review and conduct any necessary follow up discovery in responses to the documents. As the

20

supplemental responses and documents may have an impact on the need for and extent of expert

21

disclosures, the parties request that the discovery deadline for expert disclosures also be extended.

22

V.

PROPOSED SCHEDULE.

23

(a).

Discovery Cut Off: Thursday, June 28, 2018.

24

(b).

Motions to amend pleadings or add parties: No extension requested.

25

(c).

Initial Expert Disclosures: Monday, April 30, 2018 (deadline falls on a

26

Sunday).

27

(d).

Rebuttal Expert Disclosures: Thursday, May 31, 2018.

28

(e).

Interim Status Report: No extension requested.
3

44816693;1

Case 2:17-cv-01371-JCM-PAL Document 28 Filed 04/04/18 Page 4 of 4

1

(f).

Dispositive Motions: Monday, July 30, 2018 (deadlines falls on a Sunday).

2

(g).

Pretrial Order: Wednesday, August 29, 2018.

3

(h).

Extensions or Modifications of the Discovery Plan and Scheduling Order:

4

Wednesday, June 6, 2018.

5

The parties believe that the thirty (30) day extension of the discovery deadlines are necessary

6

and appropriate to provide sufficient time for plaintiff to finish gathering the requested documents

7

and supplementing their discovery responses, and to allow defendant sufficient time to review and

8

conduct any necessary follow-up on the discovery produced.

9

DATED this 3rd day of April, 2018.

AKERMAN LLP

AKERMAN LLP

ROGER P. CROTEAU & ASSOCIATES, LTD.

11
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: [phone] – FAX: [phone]

10

/s/ Jamie K. Combs________________
DARREN BRENNER, ESQ.
Nevada Bar No. 8276
JAMIE K. COMBS, ESQ.
Nevada Bar No. 13088
1635 Village Center Circle, Suite 200
Las Vegas, Nevada 89134

/s/ Robert W. Linder___________
ROGER P. CROTEAU, ESQ.
Nevada Bar No. 4958
ROBERT W. LINDER, ESQ.
Nevada Bar No. 3661
9120 W. Post Road, Suite 100
Las Vegas, NV 89148

Attorneys for Hartford Financial
Services Group, Inc., and Sentinel
Insurance Company, Ltd.

Attorneys for LV Diagnostics, LLC

12
13
14
15
16
17
18

IT IS SO ORDERED.
IT IS FURTHER ORDERED that no further extensions will be granted.

19

_________________________________________
UNITED STATES MAGISTRATE JUDGE

20

April 6, 2018
DATED: _________________________________

21
22
23
24
25
26
27
28

4
44816693;1