Lombardo v. Property and Casualty Insurance Company of Hartford et al

Filing 35

ORDER denying 34 Stipulation to Extend Deadlines; Signed by Magistrate Judge Peggy A. Leen on 12/21/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02242-JCM-PAL Document 34 Filed 12/06/18 Page 1 of 3

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Ann-Martha Andrews, SBN 7585
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
2415 East Camelback Road, Suite 800
Phoenix, Arizona 85016
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant Property and Casualty Insurance
Company of Hartford

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UNITED STATES DISTRICT COURT

Ogletree, Deakins, Nash
Smoak & Stewart, P.C.
2415 East Camelback Road, Suite 800
Phoenix, Arizona 85016

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DISTRICT OF NEVADA

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PATRICIA LOMBARDO,
Plaintiff,

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No. 2:17-CV-02242-JCM-PAL
STIPULATION TO EXTEND
DEADLINES

vs.
PROPERTY AND CASUALTY INSURANCE
COMPANY OF HARTFORD; ALE
SOLUTIONS, INC; DOES I-1 and ROES 1-5,

(SECOND REQUEST)

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Defendant.

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Plaintiff Patricia Lombardo and defendant Property and Casualty Company of

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Hartford hereby stipulate and request the Court to extend expert discovery, dispositive

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motion, and pre-trial order deadlines in this case by 45 days, resulting in the following

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changes:

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• Expert discovery deadline will be extended from January 12, 2019 through and
including February 26, 2019;
• Dispositive motion deadline will be extended from February 11, 2019 through and
including March 28, 2019.
• Pre-trial order deadline will be extended from March 13, 2019 through and
including April 29, 2019.

Case 2:17-cv-02242-JCM-PAL Document 34 Filed 12/06/18 Page 2 of 3

The parties recently mediated the case with Judge Pro. Although they were unable

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to reach a lump-sum settlement, the parties are working toward resolving this case by

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referring it to a binding, non-judicial appraisal process, but they need time to work out the

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parameters of the stipulated appraisal procedure. The parties would like to avoid the

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expenses associated with expert discovery and further trial preparation while they explore

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resolution.
The parties certify this stipulation was done in good faith and not for the purposes of

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delay.
DATED this 6th day of December 2018.

Ogletree, Deakins, Nash,
Smoak & Stewart, P.C.
2415 East Camelback road, Suite 800
Phoenix, Arizona 85016

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HAMILTON LAW LLC

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

By: /s/ Ryan Hamilton
Ryan Hamilton
5125 S. Durango, Ste. C
Las Vegas, NV 89113
Telephone: [phone]
Email: [e-mail]

By: /s/ Ann-Martha Andrews
Ann-Martha Andrews
2415 East Camelback Road, Suite 800
Phoenix, Arizona 85016
Telephone: [phone]
Email: [e-mail]

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and

Attorneys for Defendant Property and
Casualty Insurance Company of Hartford

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LAW OFFICE OF DAVID ORTIZ
David Ortiz
3950 E. Patrick Lane, Suite 201
Las Vegas, NV 89120
Telephone: [phone]
[e-mail]
Attorneys for Plaintiff Patricia
Lombardo

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Case 2:17-cv-02242-JCM-PAL Document 34 Filed 12/06/18 Page 3 of 3

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Having reviewed and considered the matter, the parties state that they recently unsuccessfully
IT IS SO ORDERED:
mediated this case, but are "working toward resolving this case by referring it to a bindind, nonjudicial appraisal process, but need more time to work out the parameters." They wish to avoid
the expense with expert discovery and further preparation while they explore resolution, but have
not provided any assurance that they have or will be able to reach a binding resolution before the
PEGGY A. scheduling order deadlines they
expiration of the third extension of the discovery plan andLEEN
UNITED STATES DISTRICT JUDGE
propose. Accordingly,

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DATED:
IT IS ORDERED that the parties' Stipulation (ECF No. 34) is DENIED without prejudice.

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Dated: December 21, 2018

___________________________
Peggy A. Leen
United States Magistrate Judge

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CERTIFICATE OF SERVICE

Ogletree, Deakins, Nash,
Smoak & Stewart, P.C.
2415 East Camelback road, Suite 800
Phoenix, Arizona 85016

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I hereby certify that I electronically transmitted the attached document to the Clerk’s

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Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing

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to the following CM/ECF registrant:

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Ryan Hamilton
HAMILTON LAW LLC
5125 S. Durango, Ste. C
Las Vegas, NV 89113
[e-mail]

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David Ortiz
LAW OFFICE OF DAVID ORTIZ
3950 E. Patrick Lane, Suite 201
Las Vegas, NV 89120
[e-mail]

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Attorneys for Plaintiff Patricia Lombardo

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DATED this 6th day of December 2018.

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/s/ Elizabeth Linville
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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36551051.1

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