Wood et al v. Nautilus Insurance Company

Filing 85

ORDER granting ECF No. 84 Stipulation for Extension of Time to Respond/Reply to ECF No. 77 Motion to Strike and 80 Motion to Dismiss Responses due by 11/28/2018. Replies due by 12/19/2018. Signed by Judge Miranda M. Du on 10/31/2018. (Copies have been distributed pursuant to the NEF - KW)

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Attorneys

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8985 S. Eastern Ave., Suite 200
Las Vegas, Nevada 89123

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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MARTIN J. KRAVITZ, ESQ.
Nevada Bar No. 83
L. RENEE GREEN, ESQ.
Nevada Bar No. 12755
KRAVITZ, SCHNITZER & JOHNSON, CHTD.
8985 So. Eastern Avenue, Suite 200
Las Vegas, Nevada 89123
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
JORDAN P. SCHNITZER, ESQ.
Nevada Bar No. 10744
THE SCHNITZER LAW FIRM
9205 W. Russell Road, Suite 240
Las Vegas, Nevada 89148
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Plaintiffs,
ROBERT “SONNY” WOOD and ACCESS MEDICAL, LLC
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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

Case No.: 2:17-cv-02393-MMD-CWH

Plaintiffs,
vs.

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NAUTILUS INSURANCE COMPANY, an
Arizona corporation; and DOES I through X,
inclusive; and ROE CORPORATIONS I through
X, inclusive,
Defendants.
STIPULATION AND [PROPOSED] ORDER FOR AN EXTENSION OF TIME FOR

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ACCESS MEDICAL, LLC AND ROBERT WOOD, II TO RESPOND TO NAUTILUS

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INSURANCE COMPANY’S MOTION TO DISMISS AND MOTION TO STRIKE AND

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FOR NAUTILUS INSURANCE COMPANY TO REPLY TO THE ACCESS MEDICAL,
LLC AND ROBERT WOOD, II’S OPPOSITIONS TO NAUTILUS INSURANCE

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COMPANY’S MOTION TO DISMISS AND MOTION TO STRIKE

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(FIRST REQUEST)

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

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extension of deadlines associated with Defendant Nautilus Insurance Company’s (“Nautilus’s”)

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Notice of Motion and Motion to Strike Allegations in Plaintiffs’ Second Amended Complaint

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and Defendant Nautilus’s Motion to Dismiss Plaintiffs Robert “Sonny” Wood and Access

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Medical, LLC’s Second Amended Complaint (collectively “Motions”), which were both filed on

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Access Medical, LLC’s Oppositions to the Motions (“Oppositions”) are due is currently
November 8, 2018. Based on the Insureds filing the Oppositions on date of the current deadline,
Nautilus’s Replies to the Insureds’ Oppositions (“Replies”) would be due on November 15,
2018.

Attorneys

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8985 S. Eastern Ave., Suite 200
Las Vegas, Nevada 89123

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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October 25, 2018. This is the first stipulation for extension of time. The date that Mr. Wood and

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The parties seek to extend the time for filing the Oppositions and Replies in order to
allow the parties an opportunity to meet and confer on the subject Motions and engage in further
meet and confer efforts regarding the parameters of the disclosure of documents during
discovery. Moreover, allowing additional time for the parties to file the applicable Oppositions
and Replies allows the parties the opportunity to fully address all of the legal issues presented.

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In light of Defendant Nautilus’s Motions, which were filed and served on October 25,
2018, the parties agree to stipulate to continue the following deadlines:

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1.

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The due date for Robert “Sonny” Wood (“Wood”) and Access Medical, LLC

(“Access”) Oppositions to the Nautilus’s Motion to Strike and Nautilus’s Motion to

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Dismiss is continued from November 8, 2018 to November 28, 2018.

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2.

The due date to Nautilus’s Replies to Wood and Access’s Oppositions to

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Nautilus’s Motion to Strike and Nautilus’s Motion to Dismiss is December 19, 2018,

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twenty-one days after the due date for the Insureds’ Oppositions.

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IT IS SO STIPULATED.
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Dated this 31st day of October, 2018.
/s/ L. Renee Green, Esq.
MARTIN J. KRAVITZ, ESQ.
Nevada Bar No. 83
L. RENEE GREEN, ESQ.
Nevada Bar No. 12755
KRAVITZ, SCHNITZER AND JOHNSON, CHTD.
8985 So. Eastern Avenue, Suite 200
Las Vegas, Nevada 89123

Attorneys for Defendant
NAUTILUS INSURANCE COMPANY

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Attorneys

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8985 S. Eastern Ave., Suite 200
Las Vegas, Nevada 89123

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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Dated this 31st day of October, 2018.
/s/ Linda Wendell Hsu, Esq.
LINDA WENDELL HSU, ESQ.
California Bar No. 162971(pro hac vice)
ERIC S. POWERS, ESQ.
Nevada Bar No.
SELMAN BREITMAN LLP
33 New Montgomery, Sixth Floor
San Francisco, CA 94105

JORDAN P. SCHNITZER, ESQ.
Nevada Bar No. 10744
THE SCHNITZER LAW FIRM
9205 W. Russell Road, Suite 240
Las Vegas, Nevada 89148
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiffs
ROBERT "SONNY" WOOD and ACCESS
MEDICAL, LLC

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ORDER

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IT IS SO ORDERED.

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Dated this 31st day of

October

, 2018.

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UNITED STATES DISTRICT COURT JUDGE

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