Opinion
2:21-cv-01537-JAD-EJY
01-11-2023
MACKENZIE STRABALA, Plaintiff v. MID-CENTURY INSURANCE COMPANY, a domestic stock; DOES I through XX, inclusive; and ROE CORPORATIONS I through XX, inclusive; Defendants.
MAINOR WIRTH, LLP BRADLEY S. MAINOR, ESQ JOSEPH J. WIRTH, ESQ ASH MARIE BLACKBURN, ESQ. Counsel for Plaintiff THE FELDMAN FIRM DAVID J. FELDMAN, ESQ. RACHEL HOLZER, ESQ. THE FELDMAN FIRM Attorneys for Defendant
MAINOR WIRTH, LLP BRADLEY S. MAINOR, ESQ JOSEPH J. WIRTH, ESQ ASH MARIE BLACKBURN, ESQ. Counsel for Plaintiff
THE FELDMAN FIRM DAVID J. FELDMAN, ESQ. RACHEL HOLZER, ESQ. THE FELDMAN FIRM Attorneys for Defendant
STIPULATION AND ORDER TO EXTEND JOINT PRETRIAL ORDER DEADLINE (FIRST REQUEST)
Pursuant to LR IA 6-1, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend the Joint Pretrial Order deadline in the above-captioned matter. Good cause exists to extend the deadline for the reasons explained below.
A. Reasons For the Extension
On August 9, 2022, deciding the matter in chambers, Judge Elayna Youchah approved a fourth stipulation and order to enlarge discovery plan and scheduling order. This stipulation set the deadline of January 12, 2023 for the Joint Pretrial Order.
Since, the parties have agreed to mediate this matter on March 27, 2023 with Ret. Judge Jennifer Togliatti. Counsel recently conferred regarding an extension of time to submit the parties' Joint Pretrial Order in light of the mediation date. The parties request that the current deadline of January 12, 2023 be extended to April 14, 2023 so that the parties are able to submit a Joint Pretrial Order after participating in mediation.
B. Proposed Revised Pretrial Order Schedule
The Joint Pretrial Order is due on January 12, 2023 and the parties are requesting the deadline be moved to April 14, 2023. This request for an extension of time is not sought for any improper purpose or delay. Rather, it is sought by the parties solely for the purpose of conducting mediation on March 27, 2022. The extension of time will allow the parties to participate in meaningful settlement negotiations through mediation. The parties reasonably believe that this matter can be resolved through mediation, thus saving the time and resources of this Court. Accordingly, the parties respectfully submit that the reasons set forth above constitute compelling reasons and good cause for the short extension.
WHEREFORE, the parties respectfully request that this Court extend the deadline for submitting their Joint Pretrial Order from the current deadline to April 14, 2023.
ORDER
IT IS SO ORDERED.