Opinion
2:20-cv-01905-KJD-DJA
11-16-2022
DEBBIE SIEGFRIED, individually, Plaintiff, v. LOYA INSURANCE COMPANY, a Foreign Corporation; and JESS LOPEZ, individually; DOES I through X; and ROE BUSINESS ENTITIES I through X, inclusive, Defendants.
DENNIS M. PRINCE KEVIN T. STRONG PRINCE LAW GROUP Attorneys for Plaintiff Debbie Siegfried KRAVITZ, SCHNITZER JOHNSON & WATSON, CHTD. M. BRADLEY JOHNSON Attorneys for Defendant Loya Insurance Company
DENNIS M. PRINCE
KEVIN T. STRONG
PRINCE LAW GROUP
Attorneys for Plaintiff
Debbie Siegfried
KRAVITZ, SCHNITZER JOHNSON & WATSON, CHTD.
M. BRADLEY JOHNSON
Attorneys for Defendant
Loya Insurance Company
JOINT MOTION TO EXTEND THE DEADLINE FOR DEFENDANT LOYA INSURANCE COMPANY TO FILE ITS REPLY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER REGARDING PLAINTIFF DEBBIE SIEGFRIED'S DEPOSITION SUBPOENA TO THE F.R.C.P. 30(B)(6) REPRESENTATIVE FOR LOYA INSURANCE COMPANY (ECF NO. 51)
(FIRST REQUEST)
DANIEL J. ALBREGTS, UNITED STATES MAGISTRATE JUDGE
Plaintiff DEBBIE SIEGFRIED (“Siegfried”), by and through her counsel of record, Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP, and Defendant LOYA INSURANCE COMPANY (“Loya”), by and through its counsel of record, M. Bradley Johnson of KRAVITZ SCHNITZER JOHNSON & WATSON, CHTD., hereby file their Joint Motion to Extend the Deadline for Defendant Loya Insurance Company to File its Reply in Support of Motion for Protective Order Regarding Plaintiff Debbie Siegfried's Deposition Subpoena to the F.R.C.P. 30(b)(6) Representative for Loya Insurance Company (First Request).
MEMORANDUM OF POINTS AND AUTHORITIES
I.
LEGAL ARGUMENT
“[D]istrict courts . . . retain broad discretion to control their dockets ....” Shahrokhi v. Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist. LEXIS 247936, at *4 (D. Nev. Dec. 30, 2021). Siegfried and Loya hereby respectfully move this Court to extend the deadline for Loya to file its Reply in Support of its Motion for Protective Order (ECF No. 51) by fourteen (14) days, from November 15, 2022 to November 29, 2022. Loya filed its Motion for Protective Order on October 25, 2022. Siegfried filed her Response on November 8, 2022 (ECF No. 53). Siegfried and Loya hereby submit this Joint Motion in accordance with LR IA 6-1. This is the parties' first joint motion for extension of time for Loya to file its Reply in Support of its Motion for Protective Order.
Siegfried and Loya respectfully request an extension of the reply deadline.Siegfried and Loya were scheduled to participate in a second mediation of this matter on November 16, 2022 in an effort to resolve this matter. However, on November 15, 2022, the parties learned that Loya's representative is unable to attend the scheduled mediation due to the death of one of his colleagues. As the parties attempt to reschedule their mediation for a separate date, Siegfried and Loya have mutually agreed to allow Loya additional time to complete its Reply because Loya devoted substantial time and resources to prepare for the second mediation. The proposed extension of time will allow Loya the requisite time to fully address the arguments Siegfried made in her Response.
Siegfried and Loya hereby file this joint motion in lieu of a stipulation because Defendant Jess Lopez is a Defendant in this action who has not filed an answer or otherwise made an appearance. See LR 7-1(c) (“A stipulation that has been signed by fewer than all the parties or their attorneys will be treated-and must be filed-as a joint motion).
II.
CONCLUSION
Based on the foregoing, Plaintiff Debbie Siegfried and Defendant Loya Insurance Company respectfully request this Court to GRANT their Joint Motion to Extend the Deadline for Defendant Loya Insurance Company to File its Reply in Support of Motion for Protective Order Regarding Plaintiff Debbie Siegfried's Deposition Subpoena to the F.R.C.P. 30(b)(6) Representative for Loya Insurance Company (First Request).
IT IS SO ORDERED.