Bridge v. Credit One Financial

Filing 98

ORDER Granting 97 Stipulation Extending Meet and Confer Deadline. Motions due by 7/24/2015. Responses due by 7/31/2015. Replies due by 8/7/2015. Signed by Magistrate Judge Nancy J. Koppe on 7/8/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01512-LDG-NJK Document 97 Filed 07/08/15 Page 1 of 3

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JOINTLY SUBMITTED
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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William Bridge, on behalf of himself and all :
others similarly situated,
:
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Plaintiff,
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vs.
:
:
Credit One Bank, N.A.,
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Defendant.
:
_______________________________________ :

Case No.: 2:14-cv-01512-LDG-NJK
STIPULATION AND [PROPOSED]
ORDER EXTENDING MEET AND
CONFER DEADLINE

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The parties to the above-captioned action respectfully jointly submit the following
Stipulation and Proposed Order for the Court’s consideration and approval:

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WHEREAS, on June 26, 2015, the Court denied without prejudice both Defendant’s motion

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for protective order and Plaintiff’s motion to compel (previously filed with the Court) and ordered

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the parties “to meet and confer to discuss their discovery disputes in light of the denial of

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Defendant’s motion to quash in the Eastern District of Pennsylvania” (Dkt. No. 93 at 4);

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WHEREAS, on June 26, 2015, the Court further ordered that, “If they are unable to resolve

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the dispute in its entirety, the parties may bring renewed discovery motions no later than July 10,

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2015,” and provided a briefing schedule for any such motions (Dkt. No. 93 at 4);

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WHEREAS, on July 1, 2015, counsel for the parties (Brian G. Anderson on behalf of

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Defendant and Kyle J. McGee on behalf of Plaintiff) met in person and discussed their respective

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positions on the discovery disputes raised in Defendant’s motion for protective order and Plaintiff’s

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motion to compel in light of the Eastern District of Pennsylvania’s May 19, 2015 ruling and

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pursuant to the Court’s order (Dkt. No. 93);

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WHEREAS, on July 2, 2015, counsel for the parties (Brian G. Anderson and R. Calder

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Huntington on behalf of Defendant and Kyle J. McGee and Diane Zilka on behalf of Plaintiff)

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conferred telephonically and further discussed their respective positions on the discovery disputes
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Case 2:14-cv-01512-LDG-NJK Document 97 Filed 07/08/15 Page 2 of 3

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raised in Defendant’s motion for protective order and Plaintiff’s motion to compel in light of the

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Eastern District of Pennsylvania’s May 19, 2015 ruling and pursuant to the Court’s order (Dkt. No.

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93);

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WHEREAS, the parties are continuing to meet and confer in good faith to resolve the

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disputes without further judicial intervention as this Court has directed and in an effort to fully

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comply with this Court’s directive;

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NOW, THEREFORE, the parties, by their respective undersigned counsel, and subject to
this Court’s approval, agree and stipulate as follows:
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The parties shall conclude their meet and confer efforts regarding the discovery

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disputes raised in Defendant’s motion for protective order (Dkt. No. 63) and Plaintiff’s motion to

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compel (Dkt. No. 88) by July 17, 2015;

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2.

If they are unable to resolve the disputes in their entirety, the parties may bring

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renewed discovery motions no later than July 24, 2015.

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according to the following schedule: response due no later than July 31, 2015, and reply due no

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later than August 7, 2015.

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DATED: July 7, 2015

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IT IS SO STIPULATED:

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SHOOK & STONE, CHTD.

GRANT & EISENHOFER P.A.

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/s/ Leonard H. Stone
LEONARD H. STONE (NV Bar No. 5791)
MICHAEL P. O’ROURKE (NV Baar No. 6764)
7109 S. Fourth Street
Las Vegas, NV 89101

/s/ Adam J. Levitt
ADAM J. LEVITT (admitted pro hac vice)
KYLE J. MCGEE (admitted pro hac vice)
30 N. LaSalle Street, Suite 2350
Chicago, IL 60602

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Attorneys for Plaintiff

Attorneys for Plaintiff

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HOLLAND & HART LLP

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/s/ Brian G. Anderson
PATRICK J. REILLY (NV Bar No. 6103)
BRIAN G. ANDERSON (NV Bar No. 10500)
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134

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Any such motions will be briefed

IT IS SO ORDERED.
DATED: July 8, 2015

Attorneys for Defendant

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NANCY J. KOPPE
United States Magistrate Judge

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