Opinion
2:21-cv-00166
04-08-2022
BRYAN HUMAN, an individual, Plaintiff, v. GEICO INSURANCE AGENCY, INC.. DOES I-X; and ROE CORPORATIONS I-X inclusive Defendants. Event Current Deadline Proposed Deadline
LESLIE MARK STOVALL, ESQ. Nevada Bar No. 2566 ROSS MOYNIHAN, ESQ. Nevada Bar No. 11848 Attorneys for Plaintiffs LARA L. MILLER, ESQ. Nevada Bar No. 12618 Attorney for Defendant
LESLIE MARK STOVALL, ESQ. Nevada Bar No. 2566 ROSS MOYNIHAN, ESQ. Nevada Bar No. 11848 Attorneys for Plaintiffs
LARA L. MILLER, ESQ. Nevada Bar No. 12618 Attorney for Defendant
STIPULATION AND ORDER TO EXTEND REBUTTAL EXPERT DEADLINE (THIRD 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 the rebuttal expert disclosure deadline by a period of seven days. Counsel for the parties have conferred regarding this matter and agree that an extension of discovery in this case is appropriate and necessary for litigation efficiency. The parties herein request an extension of the rebuttal expert disclosure deadlines by 7 days. The parties do not seek the extension or continuance of any other dates.
1. Discovery Completed to Date
At this time, all parties have exchanged initial and supplemental disclosures. The parties have propounded written discovery in the form of interrogatories, admissions, and requests for production of documents. The parties have engaged in deposition discovery and have exchanged initial expert disclosures.
2. Discovery That Remains to be Completed
The parties must exchange rebuttal expert disclosures, complete deposition discovery and generally complete remaining discovery and supplementation as needed.
3. Reasons Why Discovery Remaining Has Not Been Completed Within the Time Limits of the Court's Prior Order
The request to extend the rebuttal expert disclosure was made by plaintiff who has a retained expert whose key employee suffered an illness requiring absence from work causing the expert to devote more time than usual to his clinic and delayed work on rebuttal reporting. The Defendant agrees to the extension provided that the extension is mutual and applies also to Defendant's experts, to which the plaintiff agrees.
4. Proposed Schedule for Completion of Outstanding Discovery
The parties respectfully propose the following discovery deadlines:
Event
Current Deadline
Proposed Deadline
Last day to add parties or amend pleadings
CLOSED
CLOSED
Initial Expert Disclosures
March 8, 2022
CLOSED
Rebuttal Expert Disclosures
April 8, 2022
April 15, 2022
Close of Discovery
May 6, 2022
(Unchanged)
Dispositive Motions Deadline
June 6, 2022
(Unchanged)
ORDER
The Court having reviewed the stipulation to extend rebuttal expert deadlines in this matter, is hereby ordered that the stipulation is approved. The proposed deadlines set forth under paragraph 4 of the stipulation shall govern future discovery in this case. A separate Order shall not be issued.
IT IS SO ORDERED this 8th day of April, 2022.