Siegfried v. Lopez

1 || DENNIS M. PRINCE Nevada Bar No. 5092 || KEVIN T. STRONG Nevada Bar No. 12107 || PRINCE LAW GROUP 10801 W. Charleston Boulevard || Suite 560 Las Vegas, Nevada 89135 || Tel: (702) 534-7600 Fax: (702) 534-7601 || Email: [email protected] Attorneys for Plaintiff || Debbie Siegfried 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA DEBBIE SIEGFRIED, individually, CASE NO.: 2:20-cv-01905-KJD-DJA 11 , Plaintiff, JOINT MOTION TO EXTEND THE 12 vs. DEADLINE FOR DEFENDANT 13 LOYA INSURANCE COMPANY TO LOYA INSURANCE COMPANY, a| FILE REPLY IN SUPPORT OF 14 Foreign Corporation; and JESS LOPEZ, MOTION FOR PROTECTIVE individually; DOES I through X; and ROE ORDER REGARDING PLAINTIFF 16 inclusive, DEPOSITION SUBPOENA TO THE F.R.C.P. 30(b)(6) 17 Defendants. REPRESENTATIVE FOR LOYA 18 INSURANCE COMPANY (ECF No. 51) 19 (First Request) 20 Plaintiff DEBBIE SIEGFRIED (“Siegfried”), by and through her counsel of □□□□□ |} Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP, and Defendant LOY.

92 || INSURANCE COMPANY (“Loya”), by and through its counsel of record, M. Bradle ||Johnson of KRAVITZ SCHNITZER JOHNSON & WATSON, CHTD., hereby file thei || Joint Motion to Extend the Deadline for Defendant Loya Insurance Company to File ti Reply in Support of Motion for Protective Order Regarding Plaintiff Debbie Siegfried Deposition Subpoena to the F.R.C.P. 80(b)(6) Representative for Loya Insuranc Company (First Request). og || 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 I.

3 LEGAL ARGUMENT 4 “[Djistrict courts . . . retain broad discretion to control their dockets. . .

5 Shahrokhi v. Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist. LEXIS 247936, at * (D. Nev. Dec. 30, 2021). Siegfried and Loya hereby respectfully move this Court to exten the deadline for Loya to file its Reply in Support of its Motion for Protective Order (EC No. 51) by fourteen (14) days, from November 15, 2022 to November 29, 2022. Loya file its Motion for Protective Order on October 25, 2022. Siegfried filed her Response o November 8, 2022 (ECF No. 53). Siegfried and Loya hereby submit this Joint Motion i accordance with LR IA 6-1. This is the parties’ first joint motion for extension of time fc Loya to file its Reply in Support of its Motion for Protective Order.

12 Siegfried and Loya respectfully request an extension of the reply deadline || Siegfried and Loya were scheduled to participate in a second mediation of this matte }/on November 16, 2022 in an effort to resolve this matter. However, on November 1!

15 || 2022, the parties learned that Loya’s representative is unable to attend the schedule 1¢ || mediation due to the death of one of his colleagues. As the parties attempt to reschedul their mediation for a separate date, Siegfried and Loya have mutually agreed to allo Loya additional time to complete its Reply because Loya devoted substantial time an resources to prepare for the second mediation. The proposed extension of time will allo Loya the requisite time to fully address the arguments Siegfried made in her Respons« II.

CONCLUSION 22 Based on the foregoing, Plaintiff Debbie Siegfried and Defendant Loya □□□□□□□□□ Company respectfully request this Court to GRANT their Joint Motion to Extend th || Deadline for Defendant Loya Insurance Company to File its Reply in Support of Motio ||1 Siegfried and Loya hereby file this joint motion in lieu of a stipulation becaus Defendant Jess Lopez is a Defendant in this action who has not filed an answer c || otherwise made an appearance. See LR 7-1(c) (“A stipulation that has been signed b fewer than all the parties or their attorneys will be treated—and must be filed—as a joir || motion).

1 || for Protective Order Regarding Plaintiff Debbie Siegfried’s Deposition Subpoena to th || F.R.C.P. 30(b)(6) Representative for Loya Insurance Company (First Request).

3 || DATED this 15th day of November, 2022. DATED this 15th day of November, 2025 || PRINCE LAW GROUP KRAVITZ, SCHNITZER JOHNSON & 5 WATSON, CHTD.

7 || /s/ Kevin T. Strong /s/_M. Bradley Johnson DENNIS M. PRINCE M. BRADLEY JOHNSON || Nevada Bar No. 5092 Nevada Bar No. 4646 KEVIN T. STRONG 8985 S. Eastern Avenue |] Nevada Bar No. 12107 Suite 200 10801 W. Charleston Boulevard Las Vegas, Nevada 89123 || Suite 560 Tel: (702) 322-4126 Las Vegas, Nevada 89135 Fax: (702) 362-2203 |! Tel: (702) 534-7600 Attorneys for Defendant Fax: (702) 534-7601 Loya Insurance Company Attorneys for Plaintiff Debbie Siegfried 15 ITIS SO ORDERED.

16 DATED: November 16, 2022 17 .

18 On DANIEL J. ALBREGTS) 19 UNITED STATES MAGISTRATE JUDGE 1 CERTIFICATE OF SERVICE 2 Pursuant to LR 5-1 and FRCP 5(b), I hereby certify that I am an □□□□□□□□ || PRINCE LAW GROUP and that on the 15th day of November, 2022, I electronicall ||filed the foregoing document entitled JOINT MOTION TO EXTEND TH.

5 DEADLINE FOR DEFENDANT LOYA INSURANCE COMPANY TO FILE IT REPLY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER REGARDIN¢ PLAINTIFF DEBBIE SIEGFRIED’S DEPOSITION SUBPOENA TO TH.

F.R.C.P. 30(b)(6) REPRESENTATIVE FOR LOYA INSURANCE COMPAN (ECF No. 51) (First Request) with the Clerk of the Court using the CM/ECF systen which sent a notice of electronic filing to the following: M. Bradley Johnson ll Kristopher T. Zeppenfeld KRAVITZ, SCHNITZER & JOHNSON 12, || 8985 S. Eastern Avenue, Suite 200 Las Vegas, Nevada 89123 Tel: (702) 322-4126 Fax: (702) 362-2203 Attorneys for Defendant Loya Insurance Company 15 Pursuant to LR 5-1 and FRCP 5(b), I hereby certify that I also served the foregoin || documents via First-Class United States Mail to the following address: || Jess Lopez 8744 Raindrop Canyon || Las Vegas, Nevada 89129 21 /s/ Kevin T. Strong An Employee of Prince Law Group