Opinion
2:21-cv-00245-RFB-NJK
11-29-2022
MICHAEL BENEDICT, an individual, Plaintiff, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a Foreign Corporation; DOES I-V; and ROE CORPORATIONS VI-X, Defendants.
PRINCE LAW GROUP DENNIS M. PRINCE Nevada Bar No. 5092 KEVIN T. STRONG Nevada Bar No. 12107 -AND- CRAIG W. DRUMMOND Nevada Bar No. 11109 LIBERTY A. RINGOR Nevada Bar No. 14417 DRUMMOND LAW FIRM Attorneys for Plaintiff Michael Benedict LEWIS BRISBOIS BISGAARD & SMITH LLP ROBERT W. FREEMAN Nevada Bar No. 3062 CHERYL A. GRAMES Nevada Bar No. 12752 Attorneys for Defendant State Farm Mutual Automobile Insurance Company
PRINCE LAW GROUP DENNIS M. PRINCE Nevada Bar No. 5092 KEVIN T. STRONG Nevada Bar No. 12107 -AND- CRAIG W. DRUMMOND Nevada Bar No. 11109 LIBERTY A. RINGOR Nevada Bar No. 14417 DRUMMOND LAW FIRM Attorneys for Plaintiff Michael Benedict
LEWIS BRISBOIS BISGAARD & SMITH LLP ROBERT W. FREEMAN Nevada Bar No. 3062 CHERYL A. GRAMES Nevada Bar No. 12752 Attorneys for Defendant State Farm Mutual Automobile Insurance Company
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR PLAINTIFF MICHAEL BENEDICT TO FILE HIS RESPONSE TO DEFENDANT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY'S MOTION FOR SUMMARY JUDGMENT (ECF No. 53)
(SECOND REQUEST)
RICHARD E. BOULWARE, II United States District Court
IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff MICHAEL BENEDICT, through his counsel of record, Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP and Craig W. Drummond and Liberty A. Ringor of DRUMMOND LAW FIRM; and Defendant STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, through its counsel of record, Robert W. Freeman and Cheryl A. Grames of LEWIS BRISBOIS BISGAARD & SMITH LLP, that the deadline for Plaintiff to file his Response to Defendant State Farm Mutual Automobile Insurance Company's Motion for Partial Summary Judgment as to Plaintiff's Second, Third, Fourth, Fifth, and Sixth Causes of Action, currently scheduled for Monday, November 28, 2022, based on the parties' pending Stipulation and Order, filed October 18, 2022, shall be extended by twenty-two (22) days to Tuesday, December 20, 2022. Defendant filed its Motion for Partial Summary Judgment on October 7, 2022. This is the parties' second request for extension of time. The parties hereby submit their Stipulation and [Proposed] Order in accordance with LR IA 6-1.
The parties' first stipulation and order to extend the deadline for Plaintiff to file his Response to Defendant's Motion for Partial Summary Judgment, filed on October 18, 2022, remains pending approval. (ECF No. 55).
The parties respectfully request an additional extension of time due to extenuating circumstances. The parties originally stipulated to allow Plaintiff an extension of time to file his Response to the pending motion for partial summary judgment to accommodate a mediation that the parties scheduled for November 9, 2022 before the Honorable Justice Abbi Silver (Ret.). Unfortunately, the mediation was unable to proceed in a meaningful way due to logistical issues with the State Farm attendee. As a result, the parties rescheduled the mediation for December 6, 2022. Additionally, a miscommunication arose between Plaintiffs' respective counsels regarding the preparation of Plaintiff's Response to Defendant's Motion for Partial Summary Judgment. As a result, Defendant has agreed to allow Plaintiff additional time to prepare his Response. The parties' requested extension of time will ensure that both parties properly address the issues pending before this Court should this matter not resolve by way of the December 6, 2022 mediation.
To effectuate the purpose of the original stipulation and order submitted, the parties respectfully request this Court to approve the foregoing stipulation. The parties' requested extension is not made in bad faith or to cause any unnecessary delay.
ORDER
IT IS SO ORDERED: [55] Stipulation for Extension of time is denied as moot.