Sivil v. Country Mutual Insurance Company

Filing 31

ORDER granting 30 Stipulation - Discovery due by 12/1/2021. Motions due by 1/3/2022. Proposed Joint Pretrial Order due by 2/1/2022. Signed by Magistrate Judge Elayna J. Youchah on 9/9/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Case 2:20-cv-00244-JAD-EJY Document 31 Filed 09/09/21 Page 1 of 3 1 REBECCA L. MASTRANGELO, ESQ. 2 Nevada Bar No. 5417 ROGERS, MASTRANGELO, CARVALHO & MITCHELL 3 700 S. Third Street Las Vegas, Nevada 89101 4 Phone (702) 383-3400 Fax (702) 384-1460 5 rmastrangelo@rmcmlaw.com Attorneys for COUNTRY MUTUAL INSURANCE COMPANY 6 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 TERESA SIVIL, 11 12 13 14 15 16 17 ) ) Plaintiff, ) ) vs. ) ) COUNTRY MUTUAL INSURANCE ) COMPANY, a foreign corporation; ) DOES I through X; and ROE ) CORPORATIONS I through X, ) ) Defendants. ) ____________________________________) CASE NO. 2:20-cv-00244-JAD-EJY STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST) Pursuant to LR IA 6-1 and LR II 26-4, the parties request a sixty (60) day extension of 18 the close of discovery deadline as set forth below in order to accomplish the depositions of 19 several witnesses to the matter at issue. This stipulation is filed at least 21 days before the 20 earliest deadline sought to be extended, i.e., the close of discovery deadline, and is the parties’ 21 first request for an extension of time. In support of this request, the parties inform the Court of 22 the following: 23 The nature of this action involves a dispute over insurance coverage and allegations of 24 breach of contract, bad faith, unfair trade practices, and declaratory relief. 25 (a) Discovery completed: the parties have exchanged lists of witnesses and relevant 26 documents and have each propounded and responded to written discovery; 27 28 (b) Remaining discovery: the depositions of the parties (Plaintiff Teresa Sivil and the Fed.R.Civ.P. 30(b)(6) witness for Defendant) as well as independent witnesses Case 2:20-cv-00244-JAD-EJY Document 31 Filed 09/09/21 Page 2 of 3 1 consisting of Melissa Izatt, Sarah Muranaka, and Keith Nordlof. 2 ( c) Reason for discovery not being able to be completed by October 1, 2021 deadline: 3 the parties have been diligent in conducting discovery and the original deadline of 4 October 1, 2021, has not yet passed. However, three of the five depositions 5 needed involve witnesses located outside the State of Nevada. The parties 6 delayed scheduling those depositions due to the COVID 19 pandemic affecting in 7 person depositions and travel. Although there are still pandemic-related 8 difficulties with same, counsel believe that they will be able to proceed using 9 CDC recommended precaustions. 10 (d) Proposed schedule for completing remaining discovery: 11 12 SCHEDULED EVENT CURRENT DEADLINE PROPOSED DEADLINE Expert Disclosures CLOSED Unchanged/past Rebuttal Expert Disclosures CLOSED Unchanged/past Discovery Cutoff 10/01/2021 12/01/2021 Dispositive Motions 11/01/2021 01/03/2022 Proposed Joint Pretrial Order 12/01/2021 02/01/20221 13 14 15 16 17 18 19 / / / 20 / / / 21 / / / 22 23 24 25 26 1 27 However, if dispositive motions were to be filed, the deadline for the Proposed Joint Pretrial Order would be deferred until 30 days after the Court rules on the dispositive motions. 28 2 Case 2:20-cv-00244-JAD-EJY Document 31 Filed 09/09/21 Page 3 of 3 1 This request for an extension of time seeks sixty (60) additional days to accomplish the 2 out of state depositions and is not sought for any improper purpose including delay. 3 4 DATED this 9th day of September, 2021. BOWEN LAW OFFICES 5 ROGERS, MASTRANGELO, CARVALHO & MITCHELL 6 /s/ Rebecca Mastrangelo 7 Rebecca L. Mastrangelo, Esq. Nevada Bar No. 5417 700 S. Third Street Las Vegas, Nevada 89101 Attorney for Defendant Country Mutual Insurance Company /s/ Jerome Bowen ______________________________ Jerome Bowen, Esq. Nevada Bar No. 4540 9960 W. Cheyenne Avenue, Suite 270 Las Vegas, Nevada 89129 Attorneys for Plaintiff 8 9 10 11 12 ORDER 13 IT IS SO ORDERED this 9th day of September, 2021. 14 __________________________________ U.S. MAGISTRATE JUDGE 15 16 17 SUBMITTED BY: ROGERS, MASTRANGELO, CARVALHO 18 & MITCHELL 19 /s/ Rebecca Mastrangelo _______________________________ 20 REBECCA L. MASTRANGELO, ESQ. Nevada Bar No. 5417 21 700 S. Third Street Las Vegas, Nevada 89101 22 Attorney for Defendant Country Mutual Insurance Company 23 24 25 26 27 28 3

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