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. JOINT MOTION 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 (Fourth 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, Plaintiff and Defendant Colony Insurance Company hereby submit this Joint Motion 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 ongoing health concerns and limited staffing, the parties require additional time in order to adequately review all of the necessary documentation and respond to this Motion. Counsel for Colony recently was required to close its offices once again. In addition, Plaintiff and Defendant Colony have been actively participating in ongoing discussions and efforts to try to resolve the claims as between them.

However, given the continuing closures due to COVID-19, communication among counsel and the parties themselves has been significantly affected and delayed more than usual. The || parties would like an opportunity to fully engage in these discussions in order to either avoid || unnecessary Court time and resources or, in the alternative, in order to fully and adequately | respond to the Motion.

4 Therefore, these parties jointly request that this Court order an additional extension | of 30 days, or until July 20, 2020 to file a Response.

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

7 | This is the parties’ fourth request for an extension.

8 DATED this 19th day of June 2020.

10 BARRETT & MATURA, P.C.

11 By:___/s/ Kevin C. Barrett Kevin C. Barrett 12 7575 Vegas Drive, Suite 150c Las Vegas, NV 89128 13 Attorney for Defendant Colony Insurance Company 15 By:___/s/ Brandi M. Planet John Randall Jefferies, Esq.

16 Brandi M. Planet, Esq.

Chelsie A. Adams, Esq.

7 300 South 4" Street, 14" Floor Las Vegas, Nevada 89101 18 Attorneys for Plaintiff Arizona Civil Constructors, Inc. 20 IT IS SO ORDERED _7y Re 23 UNITED) TATES DISTRICT JUDGE Dated: June 23, 2629.