Opinion
2:21-cv-01537-CDS-EJY
10-05-2022
MACKENZIE STRABALA, Plaintiff, v. MID-CENTURY INSURANCE COMPANY, a domestic stock; DOES I through XX, inclusive; and ROE CORPORATIONS I through XX, inclusive; Defendants.
BREANNA K. HARTMANN, ESQ BRADLEY S. MAINOR, ESQ. JOSEPH J. WIRTH, ESQ. ASH MARIE BLACKBURN, ESQ. Counsel for Plaintiff David J. Feldman, Esq. Rachel J. Holzer, Esq. Attorneys for Defendant Mid- Century Insurance Co./Farmers Insurance Exchange
BREANNA K. HARTMANN, ESQ BRADLEY S. MAINOR, ESQ. JOSEPH J. WIRTH, ESQ. ASH MARIE BLACKBURN, ESQ. Counsel for Plaintiff
David J. Feldman, Esq. Rachel J. Holzer, Esq. Attorneys for Defendant Mid- Century Insurance Co./Farmers Insurance Exchange
[PROPOSED] STIPULATION FOR AN EXTENSION OF TIME TO DISCLOSE REBUTTAL EXPERTS ONLY [FIRST REQUEST]
Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and respectfully request that this Court extend the deadline for rebuttal expert reports in the above-captioned matter by 30 days. Good cause exists to extend the remaining deadlines for the reasons explained below.
1. The current rebuttal expert deadline is October 13, 2022, pursuant to the Order Granting Stipulation to Enlarge Discovery Plan and Scheduling Order [ECF 23], entered on August 9, 2022.
2. Defendant has recently become aware that one of its experts retained to prepare a rebuttal report will be unable to begin to do so until after the current deadline of October 13, 2022 due to other obligations.
3. Further, experts from both parties will need to be deposed and Defense counsel has a firm trial date of October 10, 2022 (for 10 days), in the Eighth Judicial District Court of Nevada, Case No. A-18-774460-C, Jason Miller v. Ali Bubba Group Inc. dba The Equity Group and D&L Development. Therefore, the parties request a 30-day extension of time for rebuttal expert disclosure. This would make the new deadline for the rebuttal expert disclosures November 14, 2022.
4. All other case deadlines will remain the same, pursuant to the current Discovery Plan and Scheduling Order [ECF 23].
This Request for an extension of time is not sought for any improper purpose or other purpose of delay.
WHEREFORE, the parties respectfully request that this Court extend the rebuttal expert disclosure deadline to November 14, 2022 and keep all other case deadlines in accordance with the current Discovery Plan and Scheduling Order [ECF 23].
ORDER
IT IS SO ORDERED.