Hatch v. Country Preferred Insurance Company ( 2024 )

1 || LAWRENCE RUIZ, ESQ. Nevada Bar No. 11451 2 || RUIZ LAW FIRM 3 1055 Whitney Ranch Drive, Suite 110 Henderson, NV 89014 4 || Phone: (702) 850.1717 Fax: (702) 850.1716 5 lawrence@Imruizlaw.com 6 || Attorney for Plaintiff 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 JAMIE HATCH, 10 11 Plaintiff, Case No.: 2:23-cv-01705-JAD-BNW 12 || vs. STIPULATION AND ORDER TO = EXTEND DISCOVERY DEADLINES 13 || COUNTRY PREFERRED INSURANCE Request) > 14 COMPANY, a Georgia Foreign Insurance Company; DOES 1-10; and ROE Entities 11 15 || through 20, inclusive jointly and severally, 16 Defendants. 171 GounTRY PREFERRED INSURANCE = 18 || COMPANY, an Illinois Corporation, 19 Counterclaimant, 20 vs. 21 JAMIE HATCH, 22 23 Counter- Defendant. 24 5 In accordance with Local Rules of Practice for the United States District Court for th 26 || District of Nevada ("LR") 26-4, Plaintiff Jamie Hatch ("Plaintiff"), by and through his counsel o 27 || record, LAWRENCE RUIZ, ESQ. of the RUIZ LAW FIRM, and Defendant Country Preferre 28 Insurance Company ("Defendant"), by and through their counsel of record, GINA M. 1 || MUSHMECHE, ESQ. of KRAVITZ, SCHNITZER, JOHNSON & WATSON, CHTD., hereb 2 stipulate and agree to an extension of all remaining discovery deadlines by sixty (60) days. Th 3 parties propose the following revised discovery plan (new information in bold italics): : Pursuant to Local Rule 6-1(b), the Parties hereby aver that this is the first such discove 6 extension requested in this matter. Further: 1) there is no danger of prejudice as the extension i 7 || stipulated by the Parties; 2) a sixty (60) day extension will not impact a trial date because th 8 || same has not been scheduled; and 3) the requested extension is made in good faith by bot Parties. Pioneer Investment Services v. Brunswick Associate 's, Ltd., 507 U.S. 380, 395 (1993). ll I. DISCOVERY COMPLETED TO DATE 2 1. Plaintiff served his Initial Disclosure Pursuant to FRCP 26 on December 20 14 2023; 5 = 15 2. Defendant served its Initial Disclosure Pursuant to FRCP 26 on December 26 = 16 || 2023; 7 Il. = 18 DISCOVERY TO BE COMPLETED AND REASONS 19 FOR EXTENSION OF DISCOVERY 20 Discovery to be completed includes: 21 1. Deposition of Plaintiff. 22 2. Deposition of Defendant's FRCP 30(b)(6) representative(s). 23 3. Deposition of Plaintiffs Expert. 4. Deposition of Defendant’s Expert. 6 5. Depositions of fact witnesses. 27 6. Depositions of Plaintiff's treating medical providers. 28 7. Depositions of Defendant's employees. 1 8. FRCP 26(a)(2) designation of initial and rebuttal expert witnesses. 2 9. Depositions of initial and rebuttal expert witnesses. 3 Additional written discovery and depositions as the Parties deem necessary. The Parties assert, pursuant to Local Rule 6-1, that good cause exists for the requested 6 || extension. 7 Ill. REASONS WHY DISCOVERY WAS NOT COMPLETED WITHIN TIME SET BY 0 DISCOVERYPLAN i □□□□□□□□□□□□□□□□□□□□□□□□□ The Discovery Plan and Scheduling Order was not filed in this matter until December 4 2023. With the onset of the holidays, it made scheduling depositions difficult. For the month o & 12 {| January, counsel for Defendant had to prepare for and attend trial in another matter, which she i = 13 |fcurrently still in. 14 Further, the Parties wish to investigate this case by completing the depositions o 2 important witnesses prior to initial expert disclosures in an effort to determine if resolution of thi. matter may be reached prior to incurring fees and costs associated with disclosing experts an 1 || ‘heir respective opinions. The parties have entered into this agreement in good faith and not fo 19 || purposes of delay. 20 IV. 2] DISCOVERY DEADLINES 99 Discovery cutoff: April 3, 2024 23 Amending the pleadings or adding parties: Closed 24 Initial expert disclosures: February 5, 2024 25 Rebuttal expert disclosures: March 4, 2024 Dispositive motions: May 3, 2024 28 Joint Pre-Trial Order, if no Dispositive Motions June 3, 2024 V. 2 [PROPOSED] NEW DISCOVERY DEADLINES 3 Discovery cutoff: June 3, 2024 Amending the pleadings or adding parties: Closed 6 Expert Disclosures: April 5, 2024 7 Rebuttal Disclosures: May 3, 2024 8 Dispositive motions: July 2, 2024 9 Joint Pre-Trial Order, if no Dispositive Motions August 2, 2024 10 The Parties aver that this request for extension of discovery deadlines is made by the 6. 6d x Parties in good faith and not for the purpose of delay. 12 2 13 || APPROVED AS TO FORM AND CONTENT. 14 RUIZ LAW FIRM KRAVITZ, SCHNITZER, JOHNSON & WATSON, CHTD. «(16 o 17 || /s/ Lawrence Ruiz /s/ Gina M. Mushmeche = 18 || LAWRENCE RUIZ, ESQ. GINA M. MUSHMECHE, ESQ. 19 Nevada Bar No. 11451 Nevada Bar No. 10411 1055 Whitney Ranch Drive, Suite 110 8985 S. Eastern Avenue, Suite 200 90 || Henderson, NV 89014 Las Vegas, NV 89123 Attorney for Plaintiff/Counter-Defendant Attorney for Defendant/Counterclaimant 22 IT IS SO ORDERED: 23 24 Liteon eho, —__ ITED STATES MAGISTRATE JUDGE 25 %6 Dated:_2/5/2024 27 28 Re: Hatch v. Country Gina Mushmeche Fri 2/2/2024 2:08 PM To:Tammy Wagner Ce:Lawrence Ruiz ;Courtney Cruse Confirmed. Permission to sign. Sent from my iPhone On Feb 2, 2024, at 2:07 PM, Tammy Wagner wrote: Sorry, can | confirm that | have your permission to use your e-signature? Thank you, Tammy A. Wagner, ACP Advanced Certified Paralegal/Office Administrator 1055 Whitney Ranch Drive, Suite 110 Henderson, NV 89014 702.850.1717 (p) 702.850.1716 (f) . 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