IDS Property Casualty Insurance Company v. Cunningham
Filing
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ORDER granting 16 Stipulation to Extend Discovery deadlines. Discovery due by 6/14/2021. Motions due by 7/14/2021. Signed by Magistrate Judge Cam Ferenbach on 2/17/2021. (Copies have been distributed pursuant to the NEF - DRS)
Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 1 of 5
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SAO
SEAN D. COONEY, ESQ.
NV Bar # 12945
ADAM C. EDWARDS, ESQ.
NV Bar # 15405
CARMAN COONEY FORBUSH PLLC
4045 Spencer Street Suite A47
Las Vegas, NV 89119
Telephone: (702) 421-0111
Facsimile: (702) 516-1033
service@ccfattorneys.com
Attorneys for Plaintiff
IDS Property Casualty Insurance Company
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
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IDS PROPERTY CASUALTY INSURANCE
COMPANY, a Wisconsin Corporation
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Plaintiff,
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v.
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KATLYN CUNNINGHAM, an Individual;
DOES 1-10 and ROES 1-10
Case No.:
2:20-cv-00209-JAD-VCF
STIPULATION AND ORDER TO
EXTEND DISCOVERY
DEADLINES AND CONTINUE
TRIAL
(Second Request)
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Defendants
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Plaintiff IDS Property Casualty Insurance Company, and Defendant Katlyn
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Cunningham, by and through their respective counsel of record, hereby stipulate
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and agree, according to LR 26-3, to continue the discovery dates in this matter and
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request that the court enter a new Discovery Scheduling Order containing said
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agreed-upon dates.
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///
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Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 2 of 5
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A.
STATEMENT SPECIFYING THE DISCOVERY COMPLETED:
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The following discovery has been completed by the parties:
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1. Plaintiff IDS Casualty Company’s Initial Disclosures;
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2. Defendant’s Initial Disclosures;
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3. Plaintiff IDS Casualty Company’s requests for admissions to Defendant
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Cunningham and responses thereto;
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4. Plaintiff IDS Casualty Company’s requests for production of documents to
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Defendant Cunningham and responses thereto;
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5. Plaintiff IDS Casualty Company’s interrogatories to Defendant
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Cunningham and responses thereto;
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6. Defendant’s requests for admissions to Plaintiff IDS Casualty Company
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and responses thereto;
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7. Defendant’s requests for production of documents to Plaintiff IDS
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Casualty Company and responses thereto;
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8. Defendant’s interrogatories to Plaintiff IDS Casualty Company and
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responses thereto;
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B.
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TO BE COMPLETED:
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A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS
1. Deposition of Person most knowledgeable of Plaintiff IDS Casualty
Company;
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2. Deposition of Defendant Cunningham;
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3. Plaintiff IDS Casualty Company’s designation of expert witnesses;
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
PAGE 2 OF 6
Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 3 of 5
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4. Defendant Cunningham’s designation of expert witnesses;
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5. Deposition Plaintiff IDS Casualty Company’s expert witnesses;
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6. Deposition of Defendant Cunningham’s expert witnesses;
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7. Additional Supplemental Disclosures;
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8. Any other related discovery deemed necessary.
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C.
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COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY
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ORDER:
THE REASONS WHY THE DISCOVERY REMAINING WAS NOT
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For the entirety of the case to date, the COVID-19 pandemic and the
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associated lockdowns in the State of Nevada and elsewhere have made completing
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discovery unusually difficult. It has delayed getting the necessary information to
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complete responses to interrogatories and requests for production. It has also made
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completing depositions challenging, especially where plaintiff’s personnel who
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handled the claim no longer work for plaintiff and reside outside the State of
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Nevada.
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The parties are also in the midst of a meet and confer process over responses
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to discovery that include disclosing additional information are negotiation and
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entry of a stipulated protective order.
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Finally, the parties are in the midst of settlement discussions and wish to
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avoid the cost of designating experts or the filing of dispositive motions. The
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parties anticipate the need for informal settlement discussions and, if they cannot
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resolve the matter, will seek a judicial settlement conference through the court.
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
PAGE 3 OF 6
Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 4 of 5
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D.
A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING
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DISCOVERY:
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Deadline
Old Cut-off
New Cut-off
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Initial Expert Disclosures:
02/14/2021
04/15/2021
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Rebuttal Expert Disclosure:
03/16/2021
05/14/2021
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Amend Pleadings or Add Parties:
01/14/2021
1/14/2021
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Close of Discovery:
04/15/2021
06/14/2021
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Dispositive Motion Deadline:
05/16/2021
07/14/2021
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SO, AGREED.
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DATED February 8, 2021
DATED February 8, 2021
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CARMAN COONEY FORBUSH
PLLC
CLEAR COUNSEL LAW GROUP
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SEAN D. COONEY, ESQ.
ADAM C. EDWARDS, ESQ.
Attorneys for Plaintiff
IDS Property Casualty Insurance
Company
/s/Dustin Birch, Esq.
JARED R. RICHARDS, ESQ.
DUSTIN BIRCH, ESQ.
Attorneys for Defendant
Katlyn Cunningham
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
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Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 5 of 5
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ORDER
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Upon Stipulation by Counsel for the Parties, and good cause appearing
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therefore, IT IS HEREBY ORDERED that the discovery deadline schedule shall be
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as follows:
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Initial Expert Disclosures:
04/15/2021
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Rebuttal Expert Disclosure:
05/14/2021
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Amend Pleadings or Add Parties:
1/14/2021 (no change)
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Close of Discovery:
06/14/2021
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Dispositive Motion Deadline:
07/14/2021
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IT IS SO ORDERED.
___________________________________
Cam Ferenbach
United States Magistrate Judge
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2-17-2021
Dated:_____________________________
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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
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