Castronovo-Flihan v. State Farm Mutual Automobile Insurance Company

Filing 60

ORDER Granting 59 Stipulation to Extend Time to File Joint Pre-Trial Order. Proposed Joint Pretrial Order due by 11/22/2023. Signed by Magistrate Judge Daniel J. Albregts on 11/9/2023. (Copies have been distributed pursuant to the NEF - ALZ)

1 ROBERT W. FREEMAN
Nevada Bar No. 3062
2 E-Mail: [e-mail]
FRANK A TODDRE, II
3 Nevada Bar No. 11471
E-Mail: Frank. [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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PROPOSED STIPULATION AND ORDER
TO EXTEND TIME FOR THE PARTIES
TO FILE THE JOINT PRE-TRIAL
ORDER

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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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(SECOND REQUEST)

Defendants.

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Plaintiff GINA CASTRONOVO-FLIHAN (“Plaintiff”), by and through her undersigned

19 counsel of record, and Defendant STATE FARM MUTUAL AUTOMOBILE INSURANCE
20 COMPANY (“Defendant”), by and through its undersigned counsel of record, hereby stipulate and
21 agree, subject to the Court’s approval, as follows:
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1.

On September 22, 2023, this Court entered an Order [40] Granting Motion for

23 Partial Summary Judgment. (ECF No. 54).
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2.

On October 19, 2023, Plaintiff and Defendant conducted a meet and confer to

25 discuss the Joint Pre-Trial Order.
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3.

The parties have been working diligently and have held a thorough meet and confer

27 to discuss the Joint Pre-Trial Order. However, there are certain issues the parties are negotiating

LEWIS

28 that will likely not be completed, insofar as verbiage on the contentions and discussions for exhibits

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

131741380.1

1 or factual stipulations, by the current due date of the Joint Pre-Trial Order on October 25, 2023.
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4.

On October 26, 2023, this court entered an Order [58] extending time for the parties

3 to file the Joint Pre-Trial Order.
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5.

The parties have completed a first working draft of the proposed Joint Pre-Trial

5 Order, following their meet and confer.
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6.

Plaintiff has provided a revised draft for Defendant review. Based on the length and

7 scope of additions, Defense counsel requires a brief enlargement of time to review the latest version
8 with client and to finalize for submission to Court.
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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

131741380.1

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7.

The parties agreed to extend the due date of the Joint Pre-Trial Order by ten (10)

2 days inclusive of the current due date of November 8, 2023 to November 17, 2023.
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DATED this 8th day of November, 2023.
MCMENEMY | INJURY LAW PLLC

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

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DATED this 8th day of November, 2023.
LEWIS BRISBOIS BISGAARD &
SMITH LLP

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/s/ Frank A. Toddre, II
ROBERT W. FREEMAN
Nevada Bar No. 3062
FRANK A. TODDRE, II
Nevada Bar No. 11471
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendant
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY

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ORDER
By agreement of the parties, the due date of the Joint Pre-Trial Order shall be extended by a

19 period of two weeks from November 8, 2023 to November 22, 2023.
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IT IS SO ORDERED.

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9th day of November, 2023:
DATED this _____

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________________________________
UNITED STATES
DISTRICT JUDGE
DANIEL
J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

131741380.1

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