Opinion
2:22-cv-01424-GMN-EJY
11-29-2022
SCOTT ALLAN, an individual,Plaintiff, v. PROGRESSIVE NORTHERN INSURANCE COMPANY dba PROGRESSIVE INSURANCE; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive, Defendants.
ERIC ROY LAW FIRM Stephen Lewis ERIC ROY, ESQ. Attorneys for Plaintiff BARRON & PRUITT, LLP William H. Pruitt WILLIAM H. PRUITT, ESQ. Attorneys for Defendant
ERIC ROY LAW FIRM Stephen Lewis ERIC ROY, ESQ. Attorneys for Plaintiff
BARRON & PRUITT, LLP William H. Pruitt WILLIAM H. PRUITT, ESQ. Attorneys for Defendant
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (First Request)
Defendant PROGRESSIVE NORTHERN INSURANCE COMPANY, and Plaintiff SCOTT ALLAN, through their respective counsel submit the foregoing stipulation and order to extend discovery deadlines pursuant to LR 26-4 as follows:
1. Summary of Discovery Completed
To date, the following discovery has been completed in this case:
Item
Date Completed
Plaintiff's Initial Rule 26(a) Disclosures
10/06/2022
Defendant's Initial Rule 26(a) Disclosures
11/09/2022
2. Discovery Remaining
The following discovery remains to be completed:
a) Written Discovery to be propounded by all parties;
b) Deposition of Plaintiff;
c) Deposition of Person(s) Most Knowledgeable for Defendant;
d) Deposition(s) of percipient witnesses;
e) Deposition(s) of treating physicians;
f) Disclosure of expert witnesses; and g) Deposition(s) all expert witnesses.
3. Reason Why Discovery Was Not Completed
Discovery in this matter is currently scheduled to close on February 22, 2023 with initial expert disclosures currently due by Dec. 23, 2022. Although discovery has diligently progressed since the Scheduling Order was filed on October 6, 2022, discovery has been delayed due to counsel for Defendants having recently been preparing for and in trial. Due to limitations with Counsel's schedule, additional time is needed to conduct depositions and additional discovery prior to retaining and disclosing expert witnesses. As such, the parties believe that good cause exists to justify extending the discovery deadlines and hereby request a 60 day extension of the discovery deadlines to allow for additional time to complete the remaining discovery.
4. Proposed Schedule for Completing Discovery
Accordingly, the parties respectfully request that this Court enter an order setting the following discovery plan and scheduling order dates:
Event
Former Deadline
New Deadline
Amend pleadings or add parties
November 24, 2022
No Extension Requested
Expert Designations
December 23, 2022
February 21, 2023
Rebuttal Expert Designations
January 23, 2023
March 24, 2023
Discovery Cut-off
February 22, 2023
April 24, 2023
Dispositive Motions
March 24, 2023
May 23, 2023
Joint Pre-Trial Order
April 22, 2023
June 21, 2023
Counsel further state that the requested extension of discovery deadlines is not interposed for purposes of delay, but rather for the purposes set forth above.
IT IS SO ORDERED.