Leatham et al v. Safeco Insurance Company Of America et al

Filing 39

ORDER Granting 37 Stipulation for Extension of Time (Third Request) for Defendants to File and Serve Reply in Support re 29 Motion for Summary Judgment. Replies due by 12/5/2024. Signed by Judge James C. Mahan on 11/22/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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Amy M. Samberg (NV Bar No. 10212)
[e-mail]
Lee H. Gorlin (NV Bar No. 13879)
[e-mail]
CLYDE & CO US LLP
7251 West Lake Mead Boulevard, Suite 430
Las Vegas, Nevada 89128
Telephone: [phone]
Facsimile:725-248-2907

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Attorneys for Safeco Insurance Company
of America and Safeco Insurance
Company of Illinois

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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NILE LEATHAM, and THE ESTATE OF
MARIE LEATHAM-DAVIS,

CLYDE & CO US LLP

7251 West Lake Mead Boulevard, Suite 430
Las Vegas, Nevada 89128

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CASE NO.: 2:23-cv-01432-JCM-DJA

Plaintiffs,

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v.

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SAFECO INSURANCE COMPANY OF
AMERICA, a foreign entity; SAFECO
INSURANCE COMPANY OF ILLINOIS, a
foreign entity; DOES I through X, inclusive; and
ROE CORPORATIONS I through V, inclusive,

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STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANTS
TO FILE AND SERVE REPLY IN
SUPPORT OF THEIR MOTION FOR
SUMMARY JUDGMENT
(Third Request)1

Defendants.

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Plaintiffs NILE LEATHAM (“Nile”), and THE ESTATE OF MARIE LEATHAM (the

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“Estate”) (collectively “Plaintiffs”), and Defendants SAFECO INSURANCE COMPANY OF

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ILLINOIS (“SICI”) and SAFECO INSURANCE COMPANY OF AMERICA (“SICA”)

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(collectively “Safeco,” and with collectively with Plaintiffs, the “Parties”) hereby stipulate to allow

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Safeco an extension of ten (10) days in which to file and serve its Reply in Support of its Motion

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for Summary Judgment. (ECF No. 29). The reasons supporting this stipulation are as follows:

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Defendants’ counsel has been inundated with a deluge of emergency filings in other matters, all of

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which were unexpected. In light of the unexpected volume of the filings in other matters,

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This is the third request for an extension of briefing deadlines as a whole (ECF Nos. 31 and 35),
but the first specifically related to Defendants’ Reply.

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Defendants’ counsel requires additional time to confer with their clients in preparation for their

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Reply in order to prepare a complete Reply without the need for supplemental briefing (which is

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discouraged).

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Thanksgiving Holiday wherein conferral with clients is not expected to be practicable. Defendants

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anticipate no further extensions needed.

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With this extension, Defendants’ Reply deadline would be extended from November 25,

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2024, to December 5, 2024, again accounting for the intervening Thanksgiving Weekend. This is

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the third extension of time requested by the Parties related to this Motion as a whole (ECF Nos. 31

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and 35).

CLYDE & CO US LLP

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7251 West Lake Mead Boulevard, Suite 430
Las Vegas, Nevada 89128

Finally, Defendants request a ten (10) day extension due to the intervening

IT IS STIPULATED AND AGREED by and between the parties that Defendants shall have

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up to and including December 5, 2024 to file their reply.

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Dated: November 19, 2024

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BOWEN LAW OFFICES

CLYDE & CO US LLP

By: /s/ Jerome R. Bowen
Jerome R. Bowen (NV Bar No. 4540)
9960 W. Cheyenne Avenue, Suite 250
Las Vegas, Nevada 89129

By: /s/ Lee H. Gorlin
Amy M. Samberg (NV Bar No. 10212)
Lee H. Gorlin (NV Bar No. 13879)
7251 West Lake Mead Boulevard, Suite 430
Las Vegas, Nevada 89128

Attorneys for Plaintiffs

Attorneys for Defendants

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ORDER

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IT IS SO ORDERED:
November 22, 2024
DATED: ____________________

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____________________________________
UNITED STATES DISTRICT JUDGE

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As an employee of Clyde & Co US LLP, I certify that a copy of the foregoing

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE AND

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SERVE REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT (Third

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Request) was served by the method indicated:

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CLYDE & CO US LLP

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7251 West Lake Mead Boulevard, Suite 430
Las Vegas, Nevada 89128

CERTIFICATE OF SERVICE

BY FAX: by transmitting via facsimile the document(s) listed above to the fax number(s) set
A printed
transmission record is attached to the file copy of this document(s).

? forth below on this date before 5:00 p.m. pursuant to EDCR Rule 7.26(a).

BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with postage

? thereon fully prepaid, in the United States mail at Las Vegas, Nevada addressed as set forth
below.

BY ELECTRONIC SERVICE: submitted to the above-entitled Court for electronic service

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? upon the Court’s Registered Service List for the above-referenced case.

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? individual(s) listed below.

BY EMAIL: by emailing a PDF of the document listed above to the email addresses of the

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Dated: November 19, 2024
/s/ Debbie Shuta
An Employee of Clyde & Co US LLP

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