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SCOTT ALLAN, an individual, Plaintiff, v. PROGRESSIVE NORTHERN INSURANCE COMPANY dba PROGRESSIVE INSURANCE; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive, Defendants.

ERIC ROY LAW FIRM ERIC ROY, ESQ. Nevada Bar No. 11869 SCOTT E. PHILIPPUS, ESQ. 3890 Nevada Bar No. 13223 Attorneys for Plaintiff

BARRON & PRUITT, LLP WILLIAM H. PRUITT, ESQ. Nevada Bar No. 6783 Attorneys for Defendant

STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

Defendant PROGRESSIVE NORTHERN INSURANCE COMPANY, and Plaintiff SCOTT ALLAN, through their respective counsel, submit the foregoing stipulation and order to extend discovery deadlines pursuant to LR 26-4 as follows:

1. Summary of Discovery Completed

To date, the following discovery has been completed in this case:

Item

Date Completed

Plaintiff s Initial Rule 26(a) Disclosures

10/06/2022

Defendant's Initial Rule 26(a) Disclosures

11/09/2022

Defendant's First Set of Requests for Admission,

12/07/2022

Requests for Production and Interrogatories to Plaintiff Plaintiffs First Supplemental Rule 26(a) Disclosures

12/27/2022

Plaintiffs responses to Defendant's First Set of Requests for Admission, Request for Production and Interrogatories

01/10/2023

Plaintiffs Second Supplemental Rule 26(a) Disclosures

01/10/2023

Plaintiffs First Set of Interrogatories and Requests

01/20/2023

Item

Date Completed

for Production to Defendant

Plaintiffs Supplemental Responses to Defendant's First Requests for Production of Documents and Defendant's First Set of Interrogatories

02/03/2023

Plaintiffs Third Supplemental Rule 26(a) Disclosures

02/03/2023

Deposition of Plaintiff Scott Allan

02/06/2023

Defendant's First Supplemental Rule 26(a) Disclosures

02/09/2023

Defendant's Designation of Expert Witnesses

02/21/2023

Plaintiff s Designation of Expert Witnesses

02/21/2023

Defendant's Responses to Plaintiff s First Set of Requests for Production of Documents and Answers to Plaintiffs First Set of Interrogatories

03/13/2023

Plaintiff s First Supplemental Designation of Expert Witnesses

06/23/2023

Plaintiffs Fourth Supplemental Rule 26(a) Disclosures

06/23/2023

Defendant's First Supplemental Designation of Expert Witnesses

06/23/2023

Defendant's Second Supplemental Rule 26(a) Disclosures

07/26/2023

Plaintiffs Fifth Supplemental Rule 26(a) Disclosures08/07/2023

Plaintiffs Initial Rebuttal Expert Disclosure08/23/2023

Plaintiffs First Supplemental Rebuttal Expert Disclosure

08/24/2023

Defendant's Initial Rebuttal Expert Disclosure

08/25/2023

Defendant's First Supplemental Rebuttal Expert Disclosure

08/25/2023

Plaintiffs Sixth Supplemental Rule 26(a) Disclosures

09/08/2023

Deposition of Joseph J. Schifini, MD

09/18/2023

Plaintiffs Second Supplemental Expert Disclosure

09/27/2023

Defendant's Third Supplemental Rule 26(a) Disclosures

12/12/2023

Plaintiff s Seventh Supplemental Rule 26(a)

01/22/2024

Item

Date Completed

Disclosures

Plaintiffs Second Supplemental Responses to

01/22/2024

Defendant's First Set of Interrogatories Plaintiffs Supplemental Responses to Defendant's

01/22/2024

First Requests for Production of Documents Deposition of Dr. Joseph Solberg

01/26/2024

Deposition of Steven Grimm, Ph.D.

02/08/2024

Plaintiffs Eighth Supplemental Rule 26(a) Disclosures

02/13/2024

Defendant's Third Supplemental Rule 26(a) Disclosures

03/01/2024

2. Discovery Remaining

The following discovery remains to be completed:

a) Dr. Fishell's deposition has been scheduled for March 18, 2024;
b) Dr. Garber's deposition has been scheduled for April 9, 2024;
c) Additional Written Discovery;
d) Deposition of Person(s) Most Knowledgeable for Defendant;
e) Deposition(s) of percipient witnesses;
f) Dcposition(s) of treating physicians;
g) Deposition(s) all remaining expert witnesses; and
h) Additional discovery as necessary.

3. Reason Why Discovery Was Not Completed

Discovery in this matter is currently scheduled to close on April 25, 2024. Although discovery has diligently progressed, additional time is required to complete the remaining depositions due to scheduling conflicts and delays arising from trial preparation in other matters and delays experienced with receiving Plaintiffs medical records and documents regarding an accident which occurred in 2023. As such, the parties believe that good cause exists to warrant extending the discovery cut off deadline and hereby request a 60 day extension of the remaining discovery deadlines to allow for additional time to complete the remaining discovery.

4. Proposed Schedule for Completing Discovery

Accordingly, the parties respectfully request that this Court enter an order setting the following discovery plan and scheduling order dates:

Event

Former Deadline

New Deadline

Amend pleadings or add parties

November 24, 2022

No Extension Requested

Expert Designations

June 21, 2022

No Extension Requested

Rebuttal Expert Designations

August 25, 2023

No Extension Requested

Discovery Cut-off

April 25, 2024

June 24,2024

Dispositive Motions

May 28,2024

July 29,2024

Joint Pre-Trial Order

June 25, 2024

August 26, 2024

Counsel further state that the requested extension of discovery deadlines is not interposed for purposes of delay, but rather for the purposes set forth above.

IT IS SO ORDERED.

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Allan v. Progressive N. Ins. Co.
(Mar 6, 2024)