Opinion
2:19-cv-00743-CDS-DJA [1]
12-28-2022
DENNIS M. PRINCE KEVIN T. STRONG PRINCE LAW GROUP W. Charleston Boulevard FARHAN R. NAQVI Nevada Bar No. 8589 ELIZABETH E. COATS Nevada Bar No. 12350 NAQVI INJURY LAW Attorneys for Plaintiffs Kelsy Arlitz and Gary Arlitz and Karie Arlitz as General Guardians of Kelsy Arlitz McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP Jonathan W. Carlson JAMES P. WAGONER (admitted pro hac vice) JONATHAN W. CARLSON MUNGER TOLLES & OLSON, LLP CARY B. LERMAN (admitted pro hac vice) JACOB MAX ROSEN (admitted pro hac vice) Attorneys for Defendant
DENNIS M. PRINCE
KEVIN T. STRONG
PRINCE LAW GROUP
W. Charleston Boulevard
FARHAN R. NAQVI
Nevada Bar No. 8589
ELIZABETH E. COATS
Nevada Bar No. 12350
NAQVI INJURY LAW
Attorneys for Plaintiffs
Kelsy Arlitz and Gary Arlitz and Karie Arlitz as General Guardians of Kelsy Arlitz
McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
Jonathan W. Carlson
JAMES P. WAGONER
(admitted pro hac vice)
JONATHAN W. CARLSON
MUNGER TOLLES & OLSON, LLP
CARY B. LERMAN
(admitted pro hac vice)
JACOB MAX ROSEN
(admitted pro hac vice)
Attorneys for Defendant
STIPULATION AND ORDER TO EXTEND THE BRIEFING SCHEDULE FOR DEFENDANT GEICO CASUALTY COMPANY'S PARTIAL MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER DENYING GEICO'S MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' BREACH OF CONTRACT CLAIMS (ECF NO. 190)
(FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs KELSY ARLITZ, individually; GARY ARLITZ, as general guardian of ward KELSY ARLITZ, and KARIE ARLITZ, as general guardian of ward KELSY ARLITZ (“Plaintiffs”), through their counsel of record, Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP and Farhan R. Naqvi and Elizabeth E. Coats of NAQVI INJURY LAW, and Defendant GEICO CASUALTY COMPANY (“GEICO”), through its counsel of record, James P. Wagoner and Jonathan W. Carlson of McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP and Cary B. Lerman and Jacob Max Rosen of MUNGER TOLLES & OLSON, LLP, that the deadline for Plaintiffs to file their Response to GEICO's Partial Motion for Reconsideration of this Court's Order Denying GEICO's Motion for Summary Judgment on Plaintiffs' Breach of Contact Claims (ECF No. 190) shall be extended by fourteen (14) days, from Tuesday, January 3, 2023 to Tuesday, January 17, 2023.
IT IS FURTHER STIPULATED AND AGREED that the deadline for GEICO to file its Reply in Support of its Partial Motion for Reconsideration of this Court's Order Denying GEICO's Motion for Summary Judgment on Plaintiffs' Breach of Contact Claims (ECF No. 190) shall be extended by twenty-eight (28) days from Tuesday, January 17, 2023, the date Plaintiffs file their Response. Therefore, GEICO's deadline to file its Reply shall be Tuesday, February 14, 2023.
GEICO filed its Partial Motion for Reconsideration on December 20, 2022. This is the parties' first request for extension of time. This Stipulation and [Proposed] Order is submitted in accordance with LR IA 6-1.
The parties respectfully request this brief extension of the briefing schedule to accommodate Plaintiffs' counsel. From Monday, December 12, 2022 through Thursday, December 22, 2022, Plaintiffs' counsel, Mr. Prince, conducted a trial in the matter of Crick v. In-n-Out Burgers, et al., Eighth Judicial District Court Case No. A-18-781174-C. Plaintiffs' counsel devoted substantial resources during those nearly two weeks to conduct that trial. In addition, Plaintiffs' undersigned counsel, Mr. Strong, is traveling over the holidays on a pre-planned family vacation and will not be returning to the office until Tuesday, January 4, 2023, the date after the current deadline to file Plaintiffs' Response to GEICO's Partial Motion for Reconsideration. As a result, GEICO has graciously agreed to extend the briefing schedule to accommodate Plaintiffs' counsel. ...
Based on the foregoing, the parties respectfully request this Court to approve the foregoing stipulation. The parties' requested extension is not made in bad faith or to unnecessarily delay these proceedings.
ORDER
IT IS SO ORDERED.