Opinion
2:20-cv-01383-ART-BNW
11-28-2022
PN II, INC. dba PULTE HOMES and/or DEL WEBB, a Nevada corporation, Plaintiff, v. NATIONAL FIRE & MARINE INSURANCE COMPANY; and DOES 1 through 100, inclusive, Defendants. NATIONAL FIRE & MARINE INSURANCE COMPANY, a Nebraska insurance company, Counter-Claimant, v. PN II, INC. dba PULTE HOMES and/or DEL WEBB, a Nevada corporation, Counter-Defendant. NATIONAL FIRE & MARINE INSURANCE COMPANY, a Nebraska insurance company, Third-Party Plaintiff, v. PN II, dba PULTE HOMES and/or DEL WEBB, a Nevada corporation; CONTRACTORS INSURANCE COMPANY OF NORTH AMERICA, INC., a Hawaii corporation, Third-Party Defendants.
NICOLAIDES FINK THORPE MICHAELIDES SULLIVAN LLP Jeffrey N. Labovitch Dawn A. Hove Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company SHIVES & ASSOCIATES LIMITED Martin L. Shives Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company BROWN, BONN & FRIEDMAN, LLP Thomas Friedman Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company PAYNE & FEARS LLP Scott S. Thomas Sarah J. Odia Attorneys for Plaintiff and CounterDefendant PN II, Inc. dba Pulte Homes and/or Del Webb MRV LAW, INC. Mark R. VonderHaar Attorneys for Third-Party Defendants Contractors Insurance Company of North America LEE LANDRUM & INGLE, APC Natasha Landrum Attorneys for Third-Party Defendants Contractors Insurance Company of North America
Complaint filed: July 24, 2020
NICOLAIDES FINK THORPE MICHAELIDES SULLIVAN LLP Jeffrey N. Labovitch Dawn A. Hove Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company
SHIVES & ASSOCIATES LIMITED Martin L. Shives Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company
BROWN, BONN & FRIEDMAN, LLP Thomas Friedman Attorneys for Defendant, Counterclaimant and Third-Party Plaintiff National Fire & Marine Insurance Company
PAYNE & FEARS LLP Scott S. Thomas Sarah J. Odia Attorneys for Plaintiff and CounterDefendant PN II, Inc. dba Pulte Homes and/or Del Webb
MRV LAW, INC. Mark R. VonderHaar Attorneys for Third-Party Defendants Contractors Insurance Company of North America
LEE LANDRUM & INGLE, APC Natasha Landrum Attorneys for Third-Party Defendants Contractors Insurance Company of North America
STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCLOSURE DATE (FIRST REQUEST)
TO THE HONORABLE COURT, AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Defendant/Counter-Claimant/Third-Party Plaintiff National Fire & Marine Insurance Company (“National Fire”), Plaintiffs/Counter-Defendants PN II, Inc. dba Pulte Homes and Del Webb (Collectively “Pulte”), and Third-Party Defendant Contactors Insurance Company of North America (“CICNA”), by and through their respective counsel of record, hereby STIPULATE and agree, subject to this Court's approval, to extend and continue the expert reporting date from December 9, 2022 to December 16, 2022. This is the first request for an extension specific to extend the initial expert disclosure date.
The parties continue to pursue discovery diligently and require additional time for the initial expert disclosure. The parties agreed to continue the current expert reporting date by seven (7) days to December 16, 2022, so that it follows the December 13, 2022 hearing regarding National Fire's pending motion to continue all discovery deadlines (ECF No. 59) and pending motions for protective order regarding the depositions of Martin Shives (ECF No. 57) and Scott Thomas (ECF No. 67). If the Court grants the motion to continue discovery or the motions for protective order, the parties will set new expert disclosure dates; if not, the parties will move forward with the initial expert disclosure date of December 16, 2022 granted by this stipulation.
In accordance with LR IA 6-1, there have been no prior extensions solely to extend the initial expert disclosure dates. There have been five prior stipulations for the extension of time regarding discovery deadlines. (ECF No. 52)
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED. All parties have until December 16, 2022, for initial expert disclosures.