Opinion
2:17-cv-02393-MMD-VCF
08-04-2023
ROBERT “SONNY” WOOD, an individual; ACCESS MEDICAL, LLC, a Delaware limited liability company, Plaintiffs, v. NAUTILUS INSURANCE GROUP, a Delaware limited liability company, et al., Defendant. NAUTILUS INSURANCE COMPANY, Counter-claimant, v. ROBERT “SONNY” WOOD; ACCESS MEDICAL, LLC; FLOURNOY MANAGEMENT, LLC AND ROES 1-10, inclusive, Counter-defendants.
ARMSTRONG TEASDALE LLP TRACY A. DIFILLIPPO, ESQ. Nevada Bar No. 7676 MICHELLE D. ALARIE, ESQ. Nevada Bar No. 11894 WILLIAM S. KRONENBERG, ESQ. (LR IA 11-2 admitted) California Bar No. 133730 KRONENBERG LAW PC Attorneys for Defendant/Counterclaimant Nautilus Insurance Co. THE SCHNITZER LAW FIRM JORDAN P. SCHNITZER, ESQ. NV Bar No. 10744 Attorneys for Plaintiffs Access Medical LLC & Robert Wood, II
ARMSTRONG TEASDALE LLP TRACY A. DIFILLIPPO, ESQ. Nevada Bar No. 7676 MICHELLE D. ALARIE, ESQ. Nevada Bar No. 11894 WILLIAM S. KRONENBERG, ESQ. (LR IA 11-2 admitted) California Bar No. 133730 KRONENBERG LAW PC Attorneys for Defendant/Counterclaimant Nautilus Insurance Co.
THE SCHNITZER LAW FIRM JORDAN P. SCHNITZER, ESQ. NV Bar No. 10744 Attorneys for Plaintiffs Access Medical LLC & Robert Wood, II
STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO (1) PLAINTIFFS' MOTION TO AMEND COMPLAINT AND FOR ALL ALLOWABLE DAMAGES UNDER FRCP 54(C) (ECF NO. 421); AND (2) PLAINTIFFS' MOTION TO AMEND SUMMARY JUDGMENT TO CONFORM TO EVIDENCE UNDER FRCP 52(C), FRCP 54(B), FRCP 59(B), FRCP 60(A) (ECF NO. 422) (FIRST REQUEST)
Defendant/Counter-claimant, Nautilus Insurance Company (“Nautilus”), by and through its counsel, Armstrong Teasdale LLP and William S. Kronenberg, Esq. of Kronenberg Law PC (pro hac vice), and Plaintiffs, Access Medical, LLC and Robert “Sonny” Wood, II (collectively, “Plaintiffs”), by and through their counsel, The Schnitzer Law Firm, hereby stipulate to extend the deadlines for Nautilus to respond to the following Motions: (1) Plaintiffs Motion to Amend Complaint to Conform to Evidence and For All Allowable Damages Under FRCP 54(c) filed July 19, 2023 (ECF No. 421); and (2) Plaintiffs Motion to Amend Summary Judgment to Conform to Evidence Under FRCP 52(c), FRCP 54(b), FRCP 59(b), FRCP 60(a) filed July 21, 2023 (ECF No. 422) (collectively, the “Post-trial Motions”), by approximately one week, or to August 11, 2023. The respective deadlines to respond to the Post-trial Motions are August 2, 2023, and August 4, 2023. No hearing has been set for these motions. This is Nautilus' first request to extend these deadlines.
Good cause exists to extend the response deadlines. Although Nautilus has been diligent to date in preparing its responses, Nautilus requires additional time to do so, in part, because one of its lead counsels is dealing with personal health conditions. Nautilus has requested approximately one week additional time, or to August 11, 2023, to file its responses to the Post-trial Motions, and Plaintiffs have no objection to the additional time. This request is made in good faith and is not intended to unreasonably delay this matter as Nautilus is seeking no more time that it believes is necessary.
Based on the foregoing, the parties respectfully request that this Court extend Nautilus' deadlines to file its responses to the Post-trial Motions to August 11, 2023.
ORDER
IT IS SO ORDERED.