Castronovo-Flihan v. State Farm Mutual Automobile Insurance Company

Filing 48

ORDER Granting 47 Stipulation for Extension of Time (Second Request). Replies re 40 Motion for Partial Summary Judgment due by 11/7/2022. Signed by Judge James C. Mahan on 10/28/2022. (Copies have been distributed pursuant to the NEF - TRW)

1 ROBERT W. FREEMAN
Nevada Bar No. 3062
2 E-Mail: [e-mail]
CHERYL A. GRAMES
3 Nevada Bar No. 12752
E-Mail: [e-mail]
4 LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
5 Las Vegas, Nevada 89118
TEL: [phone]
6 FAX: [phone]
Attorneys for Defendant State Farm Mutual
7 Automobile Insurance Company
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA, SOUTHERN DIVISION

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***

11 GINA CASTRONOVO-FLIHAN,

CASE NO. 2:20-cv-1197-JCM-DJA

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STIPULATION AND ORDER
TO EXTEND TIME FOR DEFENDANT
TO FILE REPLY TO PLAINTIFF’S
RESPONSE (ECF No. 45) TO
DEFENDANT’S MOTION FOR PARTIAL
SUMMARY JUDGMENT (ECF No. 40)

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Plaintiff,
vs.

14 STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, a foreign
15 company; AND DOES I through V, inclusive
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LEWIS

Defendants.

Plaintiff Gina Castronovo-Flihan (“Plaintiff”), by and through her undersigned counsel of
record, and Defendant State Farm Mutual Automobile Insurance Company (“Defendant”), by and
through its undersigned counsel of record, hereby stipulate and agree, subject to the Court’s
approval, as follows:
1.

ATTORNEYS AT LAW

On September 15, 2022, Defendant filed a Motion for Partial Summary Judgment

Pursuant to FRCP 56(d) (ECF No. 40);
2.

By stipulation and order, the deadline for Plaintiff’s Response was extended from

October 6, 2022 to October 17, 2022 and the deadline for Defendant’s Reply in support of its
Motion for Partial Summary Judgment was extended to October 31, 2022 (ECF No. 45).
3.

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BRISBOIS

BISGAARD
& SMITH LLP

(SECOND REQUEST)

4867-1978-8339.2

Plaintiff timely filed her Response (ECF No. 46) on October 17, 2022.

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4.

Based on the issues at bar in the parties’ briefing thus far, Defendant requires

2 additional time to file its reply brief, through and including November 7, 2022.
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The parties bring this stipulated request for an extension of the briefing schedule in good

4 faith, they do not interpose it for delay, and they do not file it for an improper purpose. This is the
5 second stipulation for extension of time to file Defendant’s Reply to Plaintiff’s Opposition to
6 Defendant’s Motion for Partial Summary Judgment Pursuant to FRCP 56(d).
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DATED this 26th day of October 2022.

MCMENEMY | INJURY LAW PLLC

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/s/ Ian M. McMenemy
__________________________________
IAN M. MCMENEMY, ESQ.
Nevada Bar No. 13190
8880 W. Sunset Road, Suite 130
Las Vegas, NV 89148
Attorney for Plaintiff GINA CASTRONOVOFLIHAN

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DATED this 26th day of October 2022.

LEWIS BRISBOIS BISGAARD &
SMITH LLP

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/s/ Cheryl A. Grames
__________________________________
ROBERT W. FREEMAN
Nevada Bar No. 3062
CHERYL A. GRAMES
Nevada Bar No. 12752
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendant STATE FARM
MUTUAL AUTOMOBILE INSURANCE
COMPANY

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ORDER

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IT IS SO ORDERED.

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DATED October 28, 2022.

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UNITED STATES DISTRICT JUDGE

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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4867-1978-8339.2

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