Opinion
2:21-cv-00166-RFB-EJY
10-04-2022
BRYAN HUMAN, an individual, Plaintiff, v. GEICO ADVANTAGE INSURANCE COMPANY, Inc.; DOES I-X; and ROE CORPORATIONS I-X, inclusive, Defendants.
THOMAS E. WINNER Nevada Bar No. 5168 LARA L. MILLER Nevada Bar No. 12618 WINNER, BOOZE & ZARCONE Attorneys for GEICO Advantage Insurance Company STOVALL & ASSOCIATES ROSS MOYNIHAN Nevada Bar No. 11848 Attorney for Plaintiff
THOMAS E. WINNER
Nevada Bar No. 5168
LARA L. MILLER
Nevada Bar No. 12618
WINNER, BOOZE & ZARCONE
Attorneys for GEICO Advantage Insurance Company
STOVALL & ASSOCIATES
ROSS MOYNIHAN
Nevada Bar No. 11848
Attorney for Plaintiff
STIPULATION AND ORDER TO EXTEND DEADLINE TO SUBMIT PRETRIAL ORDER (FIFTH REQUEST)
Pursuant to LR IA 6-1 and LR 26-3 and FRCP 26, the parties, by and through their respective counsel, respectfully submit this stipulation for extension of time to submit the PreTrial Order by a period of thirty (30) days. Counsel for the parties have conferred regarding this matter and agree that such an extension is appropriate and necessary for litigation efficiency. The parties herein request an extension of the deadline to submit the Pre-Trial Order by an additional thirty (30) days. The parties do not seek the extension or continuance of any other dates.
1. Discovery Completed to Date
Discovery is now closed. The parties exchanged initial and supplemental disclosures. The parties propounded written discovery in the form of interrogatories, admissions, and requests for production of documents. The parties engaged in deposition discovery and exchanged initial and rebuttal expert disclosures.
2. Discovery That Remains to be Completed
None.
3. Reasons Why Counsel Requests the Extension to Submit the Pre-Trial Order
Since participating in non-binding Mediation on August 30, 2022 and requesting the extension to submit the Joint Pretrial Order, the parties worked together to create a draft of the Joint Pretrial Order. However, they require additional time to meet and confer and to finalize the document. The parties already met telephonically one time and have another phone conference scheduled on October 11, 2022. The parties believe that the additional thirty (30) day extension of the deadline for the Pretrial Order is necessary and appropriate based upon the foregoing. The parties also believe good cause is demonstrated by the recited facts and in support of the extension of the instant deadline.
4. Proposed Schedule for Completion of Outstanding Discovery
The parties respectfully propose the following deadlines:
Event
Current Deadline
New Deadline
Last day to add parties or amend pleadings
--
Closed
Initial Expert Disclosures
--
Closed
Rebuttal Expert Disclosures
--
Closed
Close of Discovery
--
Closed
Dispositive Motions Deadline
--
Closed
Pretrial Order
October 3, 2022
November 2, 2022
ORDER
IT IS SO ORDERED.