Siegfried v. Lopez et al

Filing 57

ORDER Granting 56 Motion to Extend Time to File Reply re 51 Motion for Protective Order. Replies due by 11/29/2022. Signed by Magistrate Judge Daniel J. Albregts on 11/16/2022. (Copies have been distributed pursuant to the NEF - KF)

Case 2:20-cv-01905-KJD-DJA Document 57 Filed 11/16/22 Page 1 of 4

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DENNIS M. PRINCE
Nevada Bar No. 5092
KEVIN T. STRONG
Nevada Bar No. 12107
PRINCE LAW GROUP
10801 W. Charleston Boulevard
Suite 560
Las Vegas, Nevada 89135
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Debbie Siegfried

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DEBBIE SIEGFRIED, individually,
Plaintiff,
vs.
LOYA INSURANCE COMPANY, a
Foreign Corporation; and JESS LOPEZ,
individually; DOES I through X; and ROE
BUSINESS ENTITIES I through X,
inclusive,
Defendants.

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JOINT MOTION TO EXTEND THE
DEADLINE FOR DEFENDANT
LOYA INSURANCE COMPANY TO
FILE ITS REPLY IN SUPPORT OF
MOTION FOR PROTECTIVE
ORDER REGARDING PLAINTIFF
DEBBIE SIEGFRIED’S
DEPOSITION SUBPOENA TO THE
F.R.C.P. 30(b)(6)
REPRESENTATIVE FOR LOYA
INSURANCE COMPANY (ECF No.
51)
(First Request)

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Plaintiff DEBBIE SIEGFRIED (“Siegfried”), by and through her counsel of record,

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Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP, and Defendant LOYA

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INSURANCE COMPANY (“Loya”), by and through its counsel of record, M. Bradley

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Johnson of KRAVITZ SCHNITZER JOHNSON & WATSON, CHTD., hereby file their

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Joint Motion to Extend the Deadline for Defendant Loya Insurance Company to File its

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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135

CASE NO.: 2:20-cv-01905-KJD-DJA

Reply in Support of Motion for Protective Order Regarding Plaintiff Debbie Siegfried’s
Deposition Subpoena to the F.R.C.P. 30(b)(6) Representative for Loya Insurance
Company (First Request).
...

Case 2:20-cv-01905-KJD-DJA Document 57 Filed 11/16/22 Page 2 of 4

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MEMORANDUM OF POINTS AND AUTHORITIES

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I.

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LEGAL ARGUMENT
“[D]istrict courts . . . retain broad discretion to control their dockets . . . .”

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Shahrokhi v. Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist. LEXIS 247936, at *4
(D. Nev. Dec. 30, 2021). Siegfried and Loya hereby respectfully move this Court to extend
the deadline for Loya to file its Reply in Support of its Motion for Protective Order (ECF
No. 51) by fourteen (14) days, from November 15, 2022 to November 29, 2022. Loya filed
its Motion for Protective Order on October 25, 2022. Siegfried filed her Response on
November 8, 2022 (ECF No. 53). Siegfried and Loya hereby submit this Joint Motion in
accordance with LR IA 6-1. This is the parties’ first joint motion for extension of time for
Loya to file its Reply in Support of its Motion for Protective Order.

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Siegfried and Loya respectfully request an extension of the reply deadline.1

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Siegfried and Loya were scheduled to participate in a second mediation of this matter

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on November 16, 2022 in an effort to resolve this matter. However, on November 15,

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2022, the parties learned that Loya’s representative is unable to attend the scheduled

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mediation due to the death of one of his colleagues. As the parties attempt to reschedule

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their mediation for a separate date, Siegfried and Loya have mutually agreed to allow

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Loya additional time to complete its Reply because Loya devoted substantial time and
resources to prepare for the second mediation. The proposed extension of time will allow
Loya the requisite time to fully address the arguments Siegfried made in her Response.
II.

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CONCLUSION

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Based on the foregoing, Plaintiff Debbie Siegfried and Defendant Loya Insurance
Company respectfully request this Court to GRANT their Joint Motion to Extend the
Deadline for Defendant Loya Insurance Company to File its Reply in Support of Motion

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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135

Siegfried and Loya hereby file this joint motion in lieu of a stipulation because
Defendant Jess Lopez is a Defendant in this action who has not filed an answer or
otherwise made an appearance. See LR 7-1(c) (“A stipulation that has been signed by
fewer than all the parties or their attorneys will be treated–and must be filed–as a joint
motion).
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Case 2:20-cv-01905-KJD-DJA Document 57 Filed 11/16/22 Page 3 of 4

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for Protective Order Regarding Plaintiff Debbie Siegfried’s Deposition Subpoena to the

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F.R.C.P. 30(b)(6) Representative for Loya Insurance Company (First Request).

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DATED this 15th day of November, 2022.

DATED this 15th day of November, 2022.

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PRINCE LAW GROUP

KRAVITZ, SCHNITZER JOHNSON &
WATSON, CHTD.

/s/ Kevin T. Strong
DENNIS M. PRINCE
Nevada Bar No. 5092
KEVIN T. STRONG
Nevada Bar No. 12107
10801 W. Charleston Boulevard
Suite 560
Las Vegas, Nevada 89135
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff
Debbie Siegfried

/s/ M. Bradley Johnson
M. BRADLEY JOHNSON
Nevada Bar No. 4646
8985 S. Eastern Avenue
Suite 200
Las Vegas, Nevada 89123
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
Loya Insurance Company

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IT IS SO ORDERED.

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DATED: November 16, 2022

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____________________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135

Case 2:20-cv-01905-KJD-DJA Document 57 Filed 11/16/22 Page 4 of 4

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CERTIFICATE OF SERVICE

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Pursuant to LR 5-1 and FRCP 5(b), I hereby certify that I am an employee of

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PRINCE LAW GROUP and that on the 15th day of November, 2022, I electronically

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filed the foregoing document entitled JOINT MOTION TO EXTEND THE

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DEADLINE FOR DEFENDANT LOYA INSURANCE COMPANY TO FILE ITS
REPLY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER REGARDING
PLAINTIFF DEBBIE SIEGFRIED’S DEPOSITION SUBPOENA TO THE
F.R.C.P. 30(b)(6) REPRESENTATIVE FOR LOYA INSURANCE COMPANY
(ECF No. 51) (First Request) with the Clerk of the Court using the CM/ECF system,
which sent a notice of electronic filing to the following:
M. Bradley Johnson
Kristopher T. Zeppenfeld
KRAVITZ, SCHNITZER & JOHNSON
8985 S. Eastern Avenue, Suite 200
Las Vegas, Nevada 89123
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
Loya Insurance Company
Pursuant to LR 5-1 and FRCP 5(b), I hereby certify that I also served the foregoing

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documents via First-Class United States Mail to the following address:

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Jess Lopez
8744 Raindrop Canyon
Las Vegas, Nevada 89129

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/s/ Kevin T. Strong
An Employee of Prince Law Group

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10801 W. Charleston Blvd.
Suite 560
Las Vegas, NV 89135