Wood et al v. Nautilus Insurance Company

Filing 206

ORDER granting ECF No. 205 Stipulation : Motion for fees and costs due by 3/19/2020. Response due by 4/2/2020. Reply due by 4/9/2020. Signed by Magistrate Judge Daniel J. Albregts on 3/6/2020. (Copies have been distributed pursuant to the NEF - DRM)

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ATTORNEYS AT LAW

Selman Breitman

LLP

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GIL GLANCZ
NEVADA BAR NO. 9813
SELMAN BREITMAN LLP
33 New Montgomery, Sixth Floor
San Francisco, CA 94105-4537
Telephone:
415.979.0400
Facsimile:
415.979.2099
Email:
[e-mail]
LINDA WENDELL HSU (Pro Hac Vice)
CALIFORNIA BAR NO. 162971
PETER W. BLOOM (Pro Hac Vice)
CALIFORNIA BAR NO. 313507
SELMAN BREITMAN LLP
33 New Montgomery, Sixth Floor
San Francisco, CA 94105
Telephone:
415.979.0400
Facsimile:
415.979.2099
Email:
[e-mail]
[e-mail]
Attorneys for Defendant/Cross-Claimant
NAUTILUS INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ROBERT "SONNY" WOOD, an individual;
ACCESS MEDICAL, LLC, a Delaware limited
liability company,

v.

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STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF
DEADLINES TO MOVE FOR FEES AND
COSTS ARISING FROM NAUTILUS'S
DISCOVERY MOTIONS HEARD ON
FEBRUARY 20, 2020

Plaintiffs,

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Case No. 2:17-CV-02393-MMD-DJA

NAUTILUS INSURANCE GROUP, a
Delaware limited liability company, et al.,
Defendant.

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NAUTILUS INSURANCE COMPANY,

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Cross-Claimant,
v.
ROBERT "SONNY" WOOD; ACCESS
MEDICAL, LLC; FLOURNOY
MANAGEMENT, LLC AND ROES 1-10,
inclusive,

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Counter-Defendants.
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3892 42806 4823-6394-1302 .v1

C

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The parties hereto, by and through their undersigned counsel, stipulate for an extension of

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the deadline associated with Defendant Nautilus Insurance Company's ("Nautilus's") Request for

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Sanctions arising out of its Motion to Quash the Subpoena to the Cutler Law Firm, ECF No. 168

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and its Motion for a Protective Order, ECF No. 184 (collectively "the Motions").
In the hearing on the Motions on February 20, the Court permitted Nautilus to file a motion

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to recover fees and costs related to the Motions within 14 days. The Court also required that the

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parties meet and confer on the fees and costs issue and amounts prior to Nautilus filing the motion.

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The parties have begun the meet and confer process, but have not yet reached an agreement

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the parties request that the Court order:
1. Nautilus's motion for fees and costs, if necessary, is currently due on March 5, 2020

LLP

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but that deadline is continued to March 19, 2020.

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ATTORNEYS AT LAW

Selman Breitman

or an impasse. In light of that, and due to the current ongoing meet and confer communications,

2. Access and Wood's opposition, if necessary, is currently due on March 19, 2020, but

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that deadline is continued to April 2, 2020.

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3. Nautilus's reply, if any, is currently due March 26, 2020 but that deadline is continued

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to April 9, 2020.

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IT IS SO STIPULATED.

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DATED: March 5, 2020

SELMAN BREITMAN LLP

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By:

/s/ Linda Wendell Hsu
GIL GLANCZ
NEVADA BAR NO. 9813
LINDA WENDELL HSU (Pro Hac Vice)
CALIFORNIA BAR NO. 162971
PETER W. BLOOM (Pro Hac Vice)
CALIFORNIA BAR NO. 313507
33 New Montgomery, Sixth Floor
San Francisco, CA 94105-4537
Phone: [phone]
Facsimile: 415.979.2099
Attorneys for Defendant/Cross-Claimant
NAUTILUS INSURANCE COMPANY

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3892 42806 4823-6394-1302 .v1

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DATED: March 5, 2020

KRAVITZ, SCHNITZER & JOHNSON, CHTD

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By:

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/s/ Jordan P. Schnitzer________
JORDAN P. SCHNITZER
NEVADA BAR NO. 10744
THE SCHNITZER LAW FIRM
9205 W. Russell Road, Suite 240
Las Vegas, NV 89148
Phone: [phone]
Facsimile: [phone]
Attorneys for Defendants ACCESS MEDICAL,
LLC and ROBERT CLARK WOOD, II

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ATTORNEYS AT LAW

Selman Breitman

LLP

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IT IS SO ORDERED:
March 6, 2020
Dated: __________________

____________________________________
Magistrate Judge Daniel J. Albregts

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CERTIFICATE OF SERVICE

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ATTORNEYS AT LAW

Selman Breitman

LLP

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I hereby certify that I am an employee of SELMAN BREITMAN LLP and, pursuant to
Local Rule 5.1, service of the foregoing STIPULATION AND [PROPOSED] ORDER FOR
EXTENSION OF DEADLINES TO MOVE FOR FEES AND COSTS ARISING FROM
NAUTILUS'S DISCOVERY MOTIONS HEARD ON FEBRUARY 20, 2020 on this 5th day
of March, 2020, via the Court's CM/ECF electronic filing system addressed to all parties on the eservice list, as follows:
Martin Kravitz
L. Renee Green
KRAVITZ, SCHNITZER & JOHNSON
8985 S. Eastern Ave., Ste. 200
Las Vegas, NV 89123
Phone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

Jordan P. Schnitzer
THE SCHNITZER LAW FIRM
9205 W. Russell Road, Suite 240
Las Vegas, NV 89148
Phone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiffs ROBERT SONNY
WOOD AND ACCESS MEDICAL, LLC

Attorneys for Plaintiffs ROBERT SONNY
WOOD AND ACCESS MEDICAL, LLC

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/s/ Pamela Smith
PAMELA SMITH
An Employee of Selman Breitman LLP

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