Navigators Insurance Company v. Sparta Insurance Company

Filing 11

ORDER Granting 10 First Stipulation to Modify Scheduling Order Deadlines. Discovery due by 10/9/2018. Motions due by 11/8/2018. Proposed Joint Pretrial Order due by 12/10/2018. Signed by Magistrate Judge Carl W. Hoffman on 5/16/2018. (Copies have been distributed pursuant to the NEF - SLD)

1 Michael J. Nuñez, Esq.
Nevada Bar No. 10703
[e-mail]
2
Tyler N. Ure Esq.
3 Nevada Bar No. 11730
[e-mail]
4 MURCHISON & CUMMING, LLP
350 South Rampart Boulevard, Suite 320
5 Las Vegas, Nevada 89145
Telephone: [phone]
6 Facsimile: [phone]
7 Attorneys for Defendant,
SPARTA INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

11 NAVIGATORS INSURANCE COMPANY,
Plaintiff,

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vs.

CASE NO. 2:17-cv-02999-RFB-CWH
STIPULATION AND ORDER TO MODIFY
SCHEDULING ORDER DEADLINES
(FIRST REQUEST)

14 SPARTA INSURANCE COMPANY,
Defendant.

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STIPULATION TO MODIFY SCHEDULING ORDER DEADLINES

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This Stipulation to modify the scheduling order is entered into by and between Plaintiff

19 NAVIGATORS INSURANCE COMPANY (hereinafter "Plaintiff") and SPARTA INSURANCE
20 COMPANY (hereinafter "Defendant"), by and through their attorneys of record, pursuant to
21 LR 6-1(b) and LR 26(4) and based upon the following:
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(a)

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Plaintiff and Defendant have exchanged initial disclosures of documents and the

A statement of Discovery Completed to Date:

24 names of individuals with knowledge of the facts pertaining to Plaintiff's claims against the
25 Defendant. The Defendant has propounded written discovery requests to Plaintiff, including
26 interrogatories and requests for production, and Plaintiff has served its responses to
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Case No. 2:17-cv-02999-RFB-CWH

1 Defendant's interrogatories. The Plaintiff has propounded interrogatories and requests for
2 production to Defendant.
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A specific description of the discovery that remains to be completed
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Defendant anticipates taking the deposition of Plaintiff's FRCP 30(b)(6)
Person(s) with Knowledge.

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Plaintiff anticipates taking the depositions of Defendant's FRCP 30(b)(6)
Person(s) with Knowledge.

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Defendant anticipates taking the deposition of Plaintiff’s Expert(s).

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

Plaintiff anticipates taking the deposition of Defendant’s Expert(s).

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The Plaintiff anticipates issuing subpoenas to non-parties for business
records.

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(b)

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The reason why discovery remaining was not completed within the time
limits set by the discovery plan

The parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested

15 extension. The parties agree that, pending this Court’s approval, extension of the discovery
16 deadlines is appropriate, as the parties wish to further investigate this case, and potentially
17 reach a resolutions prior to incurring fees and costs for extensive discovery. An extension is
18 also necessary for the depositions of Defendant's and Plaintiff’s FRCP 30(b)(6) Person(s)
19 with Knowledge. Further, it has become apparent that between witness' travel plans over
20 the summer and counsel's trial calendars, it will be impractical if not impossible for the parties
21 to adequately complete discovery before the discovery deadline of July 11.
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The parties are seeking a 90 day continuance of below referenced dates:

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(c)

A proposed schedule for completing all remaining discovery:

Deadline
Expert disclosure deadline

Current Deadline Date
May 14, 2018

Extension Sought
August 13, 2018

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Rebuttal expert disclosure
deadline

June 13, 2018

September 11, 2018

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Discovery Deadline

July 11, 2018

October 9, 2018

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Case No. 2:17-cv-02999-RFB-CWH

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Dispositive Motion Deadline

August 10, 2018

November 8, 2018

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Pre-Trial Order Deadlines

September 10, 2018

December 10, 2018

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Amend Pleadings and Add April 12, 2018
Parties
Interim Status Report
May 14, 2016

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closed
August 10, 2018

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DATED: May 14, 2018

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MURCHISON & CUMMING, LLP

MORALES, FIERRO & REEVES

By: /s/ Tyler N. Ure
Michael J. Nuñez, Esq.
Nevada Bar No. 10703
Tyler N. Ure, Esq.
Nevada Bar No. 11730
350 S. Rampart Blvd., Suite 320
Las Vegas, Nevada 89145
Attorneys for Defendant

By: /s/ Ramiro Morales
Ramiro Morales, Esq.
Nevada Bar No. 7101
600 South Tonopah Drive, Suite 300
Las Vegas, Nevada 89106
Attorneys for Plaintiff

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IT IS SO ORDERED:
____________________________________
UNITED STATES MAGISTRATE JUDGE

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May 16, 2018
DATED: ____________________________

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Case No. 2:17-cv-02999-RFB-CWH