Cloud vs Allstate Indemnity Company

Filing 22

ORDER Granting 21 Stipulation for Extension of Time. Discovery due by 11/6/2024. Motions due by 12/6/2024. Proposed Joint Pretrial Order due by 1/6/2025. Signed by Magistrate Judge Daniel J. Albregts on 8/30/2024. (Copies have been distributed pursuant to the NEF - AMMi)

Marjorie Hauf, Esq.
1 Nevada Bar No.: 8111
Matthew G. Pfau, Esq.
2 Nevada Bar No.: 11439
Cara Xidis, Esq.
3 Nevada Bar No.: 11743
H&P LAW
4 710 South 9thStreet
Las Vegas, NV 89101
5 702 598 4529 TEL
702 598 3626 FAX
6 [e-mail]
Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
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DISTR ICT OF NEVADA
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***
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Courtney Cloud,
Case No.: 2:23-cv-00468-JCM-DJA
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Plaintiff,
vs.

14 Allstate Indemnity Company; Does 1
15 through 10, inclusive, and Roe
Corporations 1 through 10, inclusive,
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Stipulation and [Proposed] Order to
Extend Deadlines
(5th Request)

Defendants.
IT IS HEREBY STIPULATED AND AGREED by and between the parties hereto,
by and through their respective counsel of record, that the discovery deadlines in
this case be extended as follows:

A. COMPLETED DISCOVERY
1. Plaintiff has served her initial disclosures of witnesses and documents, and
supplements thereto;
2. Defendant has served its initial disclosures of witnesses and documents, and
supplements thereto;
3. Plaintiff has propounded and answered written discovery requests;

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4. Defendant has propounded and answered written discovery requests;

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5. Plaintiff and Defendant have disclosed their initial and rebuttal expert

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witnesses and supplements thereto;
6. Plaintiff has taken the depositions of Allstate employees Sean Owens,
Christine Fox, Jonathan Bourne, Rodney Farney and Steven Peterson;

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7. Defendant has taken the deposition of Plaintiff;

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8. Defendant has taken the deposition of Plaintiff’s experts Paul Thomas and

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Stephen Strzelec.

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10 B. OUTSTANDING DISCOVERY
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1. Deposition of the Allstate Indemnity Company’s FRCP 30(b)(6) witness;

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2. Deposition of Defendant’s expert witness Steven Plitt.

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14 C. GOOD CAUSE EXISTS FOR AN EXTENSION
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Counsel for the parties have been diligent in conducting discovery but need

16 additional time to conduct the remaining two depositions. The deposition of Allstate
17 Indemnity Company’s FRCP 30(b)(6) witness was noticed for August 1, 2024, but
18 there was a scheduling conflict, and it was rescheduled for September 26, 2024, close
19 to the close of discovery. The parties also agreed to reschedule the deposition of
20 Defendant’s expert Steven Plitt, due to scheduling conflicts earlier this month. The
21 next available date for Defendant’s expert is October 29, 2024, which is after the
22 close of discovery. Therefore, there is good cause to extend the discovery deadlines
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25 D. PROPOSED EXTENDED DEADLINES
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The parties have agreed to extend the discovery deadlines in this case, as follows:

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_____________________________________________________________
S TI P UL AT I O N TO EX T E N D D EA D L IN ES

CURRENT DEADLINE

PROPOSED DEADLINE

Motions to amend or add
parties
Initial expert disclosures

Closed

Closed

Closed

Closed

Rebuttal expert
disclosures
Close of Discovery

Closed

Closed

October 7, 2024

November 6, 2024

Dispositive motions

November 5, 2024

Pretrial Order

December 6, 2024

December 6, 2024
January 6, 2025
2024, or, if
dispositive motions are
filed, 30 days after the entry
of order on the dispositive
motions.

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Dated this 29th day of August, 2024.

Dated this 29th day of August, 2024.

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H&P LAW

KEATING LAW GROUP

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/s/ Marjorie Hauf
___________________________________
14 Marjorie Hauf, Esq.
Nevada Bar No. 8111
15 Cara Xidis, Esq.
Nevada Bar No. 11743
16 Attorneys for Plaintiff

/s/ John T. Keating
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John T. Keating, Esq.
Nevada Bar No. 6373
Attorney for Defendant

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ORDER

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IT IS SO ORDERED.

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_________________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

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DATED: 8/30/2024

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S TI P UL AT I O N TO EX T E N D D EA D L IN ES