Zervas v. USAA General Indemnity Company

Filing 63

ORDER granting 60 Stipulation re: 52 Motion to Dismiss. Replies due by 5/17/2019. Signed by Judge Jennifer A. Dorsey on 4/11/2019. (Copies have been distributed pursuant to the NEF - MMM)

1 ROBERT W. FREEMAN, ESQ.
Nevada Bar No. 003062
2 Email: [e-mail]
PRISCILLA L. O’BRIANT, ESQ.
3 Nevada Bar No. 010171
Email: [e-mail]
4 LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
5 Las Vegas, Nevada 89118
702.893.3383
6 FAX: [phone]
Attorneys for Defendant
7 USAA General Indemnity Company
8
9

UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA

11
12
13
14

EMILY ZERVAS,

CASE NO. 2:18-cv-00051-JAD-GWF

Plaintiff,
vs.

USAA GENERAL INDEMNITY COMPANY,
15 a foreign corporation doing business in
Nevada, DOES I through X and ROE
16 CORPORATIONS XI through XX,
17

STIPULATION AND ORDER TO EXTEND
DEADLINE FOR USAA’S REPLY IN
SUPPORT OF ITS MOTION FOR
SUMMARY JUDGMENT

Defendants.

18
19

IT IS HEREBY STIPULATED AND AGREED, by and between Defendant USAA

20 General Indemnity Company (“USAA”) and Plaintiff Emily Zervas (“Plaintiff”), by and
21 through their respective counsel of record:
22

-

The due date for USAA’s Reply in Support of its Motion to Dismiss (ECF No.

23 52) be extended from April 16, 2019 to May 17, 2019.
24

-

This Request for an extension of time is not sought for any improper

25 purpose or other purpose of delay.

This request for extension is based upon the

26 following:
27

LEWIS

Counsel for Defendants initiated this request because they have numerous other

28 briefings due, including for scheduled mediations, and numerous depositions, as well as

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4842-4825-4611.1

1 scheduled time off during the month of April. Additionally, the Motion to File Second
2 Amended Complaint (ECF No. 58), filed concurrently with Plaintiff’s Opposition to
3 Defendant’s Motion to Dismiss, substantive issues of law that will impact both motions,
4 and require additional briefing which will necessarily impact the Reply in Support of the
5 Motion to Dismiss. This is the first request by USAA and Plaintiff to extend this deadline,
6 which is made in good faith and not for purposes of delay.
7

WHEREFORE, the parties respectfully request that this Court extend the time for

8 USAA to file its Reply in Support of its Motion to Dismiss (ECF No. 52), from April 16,
9 2019 to May 17, 2019.
10 DATED this 10th day of April, 2019

DATED this 10th day of April, 2019

11 SCHUETZE & McGAHA, P.C.

LEWIS BRISBOIS BISGAARD & SMITH LLP

12
13
14
15
16
17

By: ___/s/ William W. McGaha______
WILLIAM W. McGAHA, ESQ.
Nevada Bar No. 003234
601 S. Rancho Drive, Suite C-20
Las Vegas, Nevada 89106
Telephone: [phone]
Attorneys for Plaintiff

18

By: ____/s/ Priscilla L. O’Briant_______
ROBERT W. FREEMAN, ESQ.
Nevada Bar No. 003062
PRISCILLA L. O’BRIANT, ESQ.
Nevada Bar No. 010171
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
Telephone: [phone]
Attorneys for Defendant
USAA General Indemnity Company

19
20

ORDER

21

IT IS SO ORDERED.

22

DATEDApril ___ 2019. __________, 2019.
Dated: this 11, day of

23
24

_________________________________
U.S. DISTRICT COURT JUDGE

25
26
27

LEWIS

28

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4842-4825-4611.1

2