Arizona Civil Constructors, Inc. v. Colony Insurance Company

1 Kevin C. Barrett, State Bar No. 8959 BARRETT & MATURA, P.C.

2 7575 Vegas Drive, Suite 150c Las Vegas, NV 89128 Telephone: (702) 833-1033 Facsimile: (602) 792-5711 Email: [email protected] Attorney for Colony Insurance Company UNITED STATES DISTRICT COURT DISTRICT OF NEVADA ARIZONA CIVIL CONSTRUCTORS, INC., a Nevada corporation, Case No. 2:20-cv-00010-JAD-DJA Plaintiff, v. STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND 12 TO MOTION FOR GOOD FAITH COLONY INSURANCE COMPANY; HDI DETERMINATION OF SETTLEMENT GLOBAL SPECIALTY SE, fka INTERNATIONAL INSURANCE (First Request) COMPANY OF HANNOVER SE; MIDWEST FAMILY MUTUAL INSURANCE COMPANY; DOES I-X, inclusive; AND ROE CORPORATIONS I-X, inclusive, 17 Defendants.

Pursuant to Local Rule 7-1 and IA 6-1, the parties hereby submit this Stipulation and Order to extend the deadline to respond to Plaintiff’s Motion for Good Faith Determination of Settlement, filed with this Court on April 10, 2020 (ECF 19). Due to the recent health concerns and limited staffing, the parties require additional time in order to respond to this Motion. In addition, Plaintiff Arizona Civil Constructors, Inc. and Defendant Colony Insurance Company (“Colony”) have agreed to engage in settlement discussions, which may affect Colony’s response to this Motion.

Therefore, the parties request that this Court order an extension of thirty (30) days in which to file a Response. Said Response will be due on May 25, 2020.

This Stipulation is submitted in good faith and not to cause any unnecessary delay.

1 This is the first request for such an extension.

2 DATED this 23rd day of April 2020.

4 BARRETT & MATURA, P.C.

5 By:___/s/ Kevin C. Barrett Kevin C. Barrett 6 7575 Vegas Drive, Suite 150c Las Vegas, NV 89128 7 Attorney for Defendant Colony Insurance Company 9 By:___/s/ Brandi M. Planet John Randall Jefferies, Esq.

10 Brandi M. Planet, Esq.

Chelsie A. Adams, Esq. ll 300 South 4" Street, 14 Floor Las Vegas, Nevada 89101 Attorneys for Plaintiff Arizona Civil Constructors, Inc. 13 By:___/s/ Dione C. Wrenn 14 Robert S. Schumacher Dione C. Wrenn 15 300 South 4" Street, Suite 1550 Las Vegas, Nevada 89101 16 Attorneys for Defendant Midwest Family Mutual Insurance Company IT IS SO ORDERED 22 __ 7 he UNITED 8TATES DISTRIGT JUDGE 23 Dated: AprivZ7, 2020.