Opinion
2:19-cv-2016-KJD-DJA
04-28-2022
UNITED STATES ex rel. FOOTHILLS ENERGY SERVICES, INC., a Colorado corporation, Plaintiff, v. PHILADELPHIA INDEMNITY INSURANCE COMPANY, a Pennsylvania corporation; SAYERS CONSTRUCTION, LLC, a Texas limited liability company; Defendants.
Phillip A. Silvestri, Esq. Nevada Bar No. 11276 Greenspoon Marder LLP Colin P. Baumchen, Esq. (Pro Hac Vice) Amanda C. Hoberg, Esq, (Pro Hac Vice) Woods Aitken, LLP Attorneys for Plaintiff Griffith Barbee PLLC Casey Griffith, Esq. (pro hac vice) Maeghan Whitehead, Esq. (pro hac vice) Karl O. Riley NV Bar No. 12077 Cozen O'Connor Attorneys for Sayers Willi Siepmann, Esq. NV Bar No. 2478 Faux Law Group Attorney for Philadelphia
Phillip A. Silvestri, Esq.
Nevada Bar No. 11276
Greenspoon Marder LLP
Colin P. Baumchen, Esq.
(Pro Hac Vice)
Amanda C. Hoberg, Esq,
(Pro Hac Vice)
Woods Aitken, LLP
Attorneys for Plaintiff
Griffith Barbee PLLC
Casey Griffith, Esq. (pro hac vice)
Maeghan Whitehead, Esq. (pro hac vice)
Karl O. Riley
NV Bar No. 12077
Cozen O'Connor
Attorneys for Sayers
Willi Siepmann, Esq.
NV Bar No. 2478
Faux Law Group
Attorney for Philadelphia
STIPULATED MOTION FOR EXTENSION OF TIME TO FILE PROPOSED TRIAL MANAGEMENT ORDER (FIRST REQUEST)
DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE
Plaintiff, Foothills Energy Services, Inc. (“Foothills”), and Defendants, Philadelphia Indemnity Insurance Company (“Philadelphia”) and Sayers Construction, LLC (“Sayers”) (collectively, “the parties”), by and through their attorneys, respectfully move this Court to enter an order granting an extension of time to file a proposed Trial Management Order until July 15, 2 2022 for the parties to complete mediation. Pursuant to Local Rules IA 6-1 and IA 26-3, 3 Foothills states as follows:
1. Trial is not set in this matter.
2. The deadline for filing a proposed trial management order is April 25, 2022.
3. Although they have not confirmed a specific date, the parties have agreed to participate in mediation in June 2022 in hopes of resolving their dispute.
4. Accordingly, the parties request that the deadline to file a proposed Trial Management Order be extended until July 15, 2022.
5. No previous extensions related to the subject deadline have been requested and permitting the opportunity for mediation constitutes good cause because it will permit the parties to continue on-going efforts to resolve the matter.
WHEREFORE, Foothills, Philadelphia and Sayers respectfully request that the Court enter an order extending the deadline for filing the proposed Trial Management Order from April 25, 2022 to July 15, 2022.
ORDER
IT IS SO ORDERED. Joint Pretrial Order due July 15, 2022.