Purvis v. Experian Information Solutions Inc et al

Filing 62

STIPULATION AND ORDER TO MODIFY CASE SCHEDULING ORDER. Signed by Judge Richard Seeborg on 12/27/12. (cl, COURT STAFF) (Filed on 12/27/2012)

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Angela M. Taylor (State Bar No. 210425)
JONES DAY
3161 Michelson Drive, Suite 800
Irvine, CA 92612
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Attorney for Defendant
EXPERIAN INFORMATION SOLUTIONS,
INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Stephanie B. Purvis,

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Plaintiff,

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vs.

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Experian Information Solutions, Inc.,
Equifax Information Services LLC, and
Trans Union, LLC,

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Defendants.

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Case No.: C 11-06352 RS
STIPULATION TO MODIFY CASE
SCHEDULING ORDER;
[PROPOSED] ORDER
[CIVIL L.R. 6-1; 6-2; 7-12]

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Pursuant to Local Rule 6-2, Plaintiff Stephanie Purvis (“Plaintiff”) and Defendants

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Experian Information Solutions, Inc. (“Experian”), Equifax Information Services LLC

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(“Equifax”), and Trans Union LLC (“Trans Union”), (collectively, “the Parties”), by and through

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their undersigned attorneys of record, hereby stipulate to modify the Court’s April 19, 2012

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Scheduling Order in this Matter (Docket No. 33), to extend the discovery cut-off and pretrial

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deadlines by 45 days.

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The current discovery deadlines in this case are as follows:

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1. Discovery cutoff date: January 18, 2013,

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2. Expert Witness Reports due February 8, 2013,
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3. Rebuttal Expert Witness Reports due March 1, 2013,

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4. Expert witness discovery to be completed by March 22, 2013, and

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5. All pretrial motions shall be heard by April 18, 2013.

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The parties are requesting a 45 day extension, which would make the new deadlines as
follows:

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1. Discovery cutoff date: March 4, 2013,

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2. Expert Witness Reports due March 25, 2013,

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3. Rebuttal Expert Witness Reports due April 15, 2013,

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4. Expert witness discovery to be completed by May 6, 2013, and

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5. All pretrial motions shall be heard by May 30, 2013.
The Parties are currently engaged in written discovery and are scheduling depositions.

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Experian’s 30(b)(6) witness is currently out on medical leave, after undergoing back surgery in

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December 2012. Although it was originally anticipated that Experian’s witness would be

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returning to work in early January 2013, it now appears that Experian’s witness will not be

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returning to work until late January 2013. A 45 day extension of the discovery and pretrial

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deadlines will give the parties additional time to schedule and conduct Experian’s 30(b)(6)

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deposition.

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The Parties have not previously requested any time modifications from the Court. The

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Parties are not seeking to reschedule the further Case Management Conference currently

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scheduled for January 31, 2013 at 10:00 am.

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As such, the Parties respectfully request a 45 day extension the of discovery and pretrial
deadlines as indicated above.
IT IS SO STIPULATED.

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Dated: December 27, 2012

JONES DAY

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By: /s/ Angela M. Taylor
Angela M. Taylor

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Attorney for Defendant
EXPERIAN INFORMATION SOLUTIONS,
INC.

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Dated: December 27, 2012

ANDERSON, OGILVIE & BREWER LLP

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By: /s/ Mark F. Anderson
Mark F. Anderson

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Attorney for Plaintiff
Stephanie Purvis

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Dated: December 27, 2012

KING & SPALDING LLP

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By: /s/ Lewis P. Perling
Lewis P. Perling

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Attorney for Defendant
Equifax Information Services LLC

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Dated: December 27, 2012

SCHUCKIT & ASSOCIATES, P.C.

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By: /s/ Robert J. Schuckit
Robert J. Schuckit

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Attorney for Defendant
Trans Union LLC

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ORDER

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PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS SO

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ORDERED
Dated: December 27 2012
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IT IS SO ORDERED

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HON. RICHARD SEEBORG

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UNITED STATES DISTRICT JUDGE

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