Opinion
2:23-cv-00050-ART-NJK
08-14-2023
LING CAI, individually; JING XU, individually; Z.X., a minor, by and through his Natural Parent, JING XU; TAMMY HARLESS, as Special Administrator of the ESTATE OF ZHONGPING ZHOU, deceased; Plaintiffs, v. ENTERPRISE LEASING COMPANY-WEST LLC dba ENTERPRISE dba ALAMO; ELCO ADMINISTRATIVE SERVICES COMPANY; ACE AMERICAN INSURANCE COMPANY; ESIS INC, dba CHUBB NORTH AMERICAN CLAIMS; CHUBB SERVICES CORPORATION dba CHUBB NORTH AMERICAN CLAIMS; CHUBB NATIONAL INSURANCE COMPANY; AND CHUBB INDEMNITY INSURANCE COMPANY; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive, Defendants.
GREENBERG TRAURIG, LLP, Eric W. Swanis, Esq. Nevada Bar No. 6840Bethany L. Rabe, Esq. Nevada Bar No. 11691 Counsel for Enterprise Defendants THE 702 FIRM, Bradley J. Meyers Nevada Bar No. 8857, Michael C. Kane Nevada Bar No. 10096 Counsel for Plaintiffs CLYDE & CO U.S. LLP Amy M. Samberg Nevada Bar No. 10212 Dylan P. Todd Nevada Bar No. 10456 Counsel for Ace Defendants
GREENBERG TRAURIG, LLP, Eric W. Swanis, Esq. Nevada Bar No. 6840Bethany L. Rabe, Esq. Nevada Bar No. 11691 Counsel for Enterprise Defendants
THE 702 FIRM, Bradley J. Meyers Nevada Bar No. 8857, Michael C. Kane Nevada Bar No. 10096 Counsel for Plaintiffs
CLYDE & CO U.S. LLP Amy M. Samberg Nevada Bar No. 10212 Dylan P. Todd Nevada Bar No. 10456 Counsel for Ace Defendants
ORDER TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT [FIRST REQUEST]
Defendants Enterprise Leasing Company-West LLC dba Enterprise dba Alamo and ELCO Administrative Services Company (collectively, the “Enterprise Parties”) by and through their counsel, the law firm of Greenberg Traurig, LLP, and Defendant ACE American Insurance Company (“AAIC”), improperly and collectively named as ACE American Insurance Company; ESIS Inc, dba Chubb North American Claims; Chubb Services Corporation dba Chubb North American Claims; Chubb National Insurance Company; and Chubb Indemnity Insurance Company (collectively “ACE Defendants”), by and through their counsel, Clyde & Co. U.S. LLP, and Plaintiffs Ling Cai, Jing Xu, Z.X., Tammy Harless, as Special Administrator of the Estate of Zhongping Zhou (“Plaintiffs”), by and through their counsel, The 702 Firm, (collectively, the “Parties,”) hereby stipulate to extend the deadline for Defendants to file their respective responses to the Second Amended Complaint to October 10, 2023 to permit the Parties to schedule and attend mediation.
Currently, Defendants' responses to the Second Amended Complaint are due on August 15,2023. However, the Parties believe that mediation could potentially lead to a global settlement of this matter without further litigation. The parties are discussing the possibility of an early mediation, and a proposed mediation date with the Hon. Jackie Glass (ret. has been presented for September 21,2023. The parties anticipate that finalizing this potential mediation in the coming days. As such, the Parties stipulate and agree to this extension so that they may attend mediation in September 2023 and avoid potentially unnecessary fees and costs. Such mediation may obviate the need for such a response. The Parties agree that Defendants will have until October 10, 2023, to file either a joint status report regarding settlement or their responses to Plaintiff's Second Amended Complaint in the event mediation is unsuccessful.
This stipulation is made in good faith and not for purposes of delay.
IT IS SO STIPULATED.
IT IS SO ORDERED.