IDS Property Casualty Insurance Company v. Cunningham

Filing 17

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)

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Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 1 of 5 1 2 3 4 5 6 7 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 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA 9 10 11 IDS PROPERTY CASUALTY INSURANCE COMPANY, a Wisconsin Corporation 12 Plaintiff, 13 v. 14 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) 15 Defendants 16 17 18 Plaintiff IDS Property Casualty Insurance Company, and Defendant Katlyn 19 Cunningham, by and through their respective counsel of record, hereby stipulate 20 and agree, according to LR 26-3, to continue the discovery dates in this matter and 21 request that the court enter a new Discovery Scheduling Order containing said 22 agreed-upon dates. 23 /// 24 25 Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 2 of 5 1 A. STATEMENT SPECIFYING THE DISCOVERY COMPLETED: 2 The following discovery has been completed by the parties: 3 1. Plaintiff IDS Casualty Company’s Initial Disclosures; 4 2. Defendant’s Initial Disclosures; 5 3. Plaintiff IDS Casualty Company’s requests for admissions to Defendant 6 Cunningham and responses thereto; 7 4. Plaintiff IDS Casualty Company’s requests for production of documents to 8 Defendant Cunningham and responses thereto; 9 5. Plaintiff IDS Casualty Company’s interrogatories to Defendant 10 Cunningham and responses thereto; 11 6. Defendant’s requests for admissions to Plaintiff IDS Casualty Company 12 and responses thereto; 13 7. Defendant’s requests for production of documents to Plaintiff IDS 14 Casualty Company and responses thereto; 15 8. Defendant’s interrogatories to Plaintiff IDS Casualty Company and 16 responses thereto; 17 B. 18 TO BE COMPLETED: 19 20 A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS 1. Deposition of Person most knowledgeable of Plaintiff IDS Casualty Company; 21 2. Deposition of Defendant Cunningham; 22 3. Plaintiff IDS Casualty Company’s designation of expert witnesses; 23 24 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 1 4. Defendant Cunningham’s designation of expert witnesses; 2 5. Deposition Plaintiff IDS Casualty Company’s expert witnesses; 3 6. Deposition of Defendant Cunningham’s expert witnesses; 4 7. Additional Supplemental Disclosures; 5 8. Any other related discovery deemed necessary. 6 C. 7 COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY 8 ORDER: THE REASONS WHY THE DISCOVERY REMAINING WAS NOT 9 For the entirety of the case to date, the COVID-19 pandemic and the 10 associated lockdowns in the State of Nevada and elsewhere have made completing 11 discovery unusually difficult. It has delayed getting the necessary information to 12 complete responses to interrogatories and requests for production. It has also made 13 completing depositions challenging, especially where plaintiff’s personnel who 14 handled the claim no longer work for plaintiff and reside outside the State of 15 Nevada. 16 The parties are also in the midst of a meet and confer process over responses 17 to discovery that include disclosing additional information are negotiation and 18 entry of a stipulated protective order. 19 Finally, the parties are in the midst of settlement discussions and wish to 20 avoid the cost of designating experts or the filing of dispositive motions. The 21 parties anticipate the need for informal settlement discussions and, if they cannot 22 resolve the matter, will seek a judicial settlement conference through the court. 23 24 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 1 D. A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING 2 DISCOVERY: 3 Deadline Old Cut-off New Cut-off 4 Initial Expert Disclosures: 02/14/2021 04/15/2021 5 Rebuttal Expert Disclosure: 03/16/2021 05/14/2021 6 Amend Pleadings or Add Parties: 01/14/2021 1/14/2021 7 Close of Discovery: 04/15/2021 06/14/2021 8 Dispositive Motion Deadline: 05/16/2021 07/14/2021 9 SO, AGREED. 10 DATED February 8, 2021 DATED February 8, 2021 11 CARMAN COONEY FORBUSH PLLC CLEAR COUNSEL LAW GROUP 12 13 14 15 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 16 17 18 19 20 21 22 23 24 STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES PAGE 4 OF 6 Case 2:20-cv-00209-JAD-VCF Document 17 Filed 02/17/21 Page 5 of 5 1 ORDER 2 Upon Stipulation by Counsel for the Parties, and good cause appearing 3 therefore, IT IS HEREBY ORDERED that the discovery deadline schedule shall be 4 as follows: 5 Initial Expert Disclosures: 04/15/2021 6 Rebuttal Expert Disclosure: 05/14/2021 7 Amend Pleadings or Add Parties: 1/14/2021 (no change) 8 Close of Discovery: 06/14/2021 9 Dispositive Motion Deadline: 07/14/2021 10 11 12 13 14 15 IT IS SO ORDERED. ___________________________________ Cam Ferenbach United States Magistrate Judge 16 17 2-17-2021 Dated:_____________________________ 18 19 20 21 22 23 24 STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES PAGE 5 OF 6

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