Lee C. Kamimura v. Green Tree Services, LLC

Filing 24

ORDER Granting 20 Stipulation for Extension of Deadline to File Rule 26 Joint Discovery Plan. Signed by Magistrate Judge Carl W. Hoffman on 8/19/16. (Copies have been distributed pursuant to the NEF - ADR)

1 LAURA R. JACOBSEN
NV Bar No. 13699
2 McDONALD CARANO WILSON LLP
100 W. Liberty St., 10th Floor
3 P.O. Box 2670
Reno, Nevada 89505
4 Telephone: [phone]
Facsimile: [phone]
5 [e-mail]
6 JOHN B. SULLIVAN, Pro Hac Vice Pending
CA Bar No. 96742
7 DONALD H. CRAM, Pro Hac Vice Pending
CA Bar No. 160004
8 MARY KATE KAMKA, Pro Hac Vice Pending
CA Bar No. 282911
9 SEVERSON & WERSON
A Professional Corporation
10 One Embarcadero Center, Suite 2600
San Francisco, California 94111
11 Telephone: [phone]
Facsimile: [phone]
12 [e-mail]
[e-mail]
13 [e-mail]
14 Attorneys for Defendant Green Tree
Servicing LLC now known as Ditech
15 Financial LLC (erroneously named as
Green Tree Services, LLC)
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17

UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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20 Lee C. Kamimura, individually and all
others similarly situated,
21
Plaintiff,
22
vs.
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Green Tree Services, LLC,
24
Defendant.
25
26

Case No. 2:16-cv-00783-APG-CWH
STIPULATION FOR EXTENSION
OF DEADLINE TO FILE RULE 26
JOINT DISCOVERY PLAN
1ST REQUEST TO EXTEND
DEADLINE TO SUBMIT RULE 26
JOINT DISCOVERY PLAN

Defendant Green Tree Servicing LLC, now known as Ditech Financial LLC

27 (“Ditech”) and Plaintiff Lee C. Kamimura (“Plaintiff”), collectively referred to
28 herein as the “Parties,” hereby stipulate to the following:
11293.0677/8301402.1

2:16-cv-00783-APG-CWH
STIPULATION

1

1.

Plaintiff filed her Class Action Complaint For Damages Pursuant To

2 The Fair Credit Reporting Act, 15 U.S.C. § 1681, Et Seq. (“Complaint”) against
3 Defendant on April 8, 2016.
4

2.

On May 2, 2016, Plaintiff filed a First Amended Complaint.

5

3.

Plaintiff served Ditech with the First Amended Complaint on May 10,

4.

On June 30, 2016, Ditech filed its motion to dismiss Plaintiff’s First

6 2016.
7

8 Amended Complaint.
9

5.

The Parties have held their discovery conference under Fed. R. Civ. P.

10 26(f) within 30 days after Ditech’s motion to dismiss.
11

6.

On July 15, 2016, Plaintiff filed a Second Amended Complaint

12 (“SAC”). ECF NO. 16.
13

7.

Ditech’s response to Plaintiff’s SAC is due on August 22, 2016. ECF

14 No. 18.
15

8.

After meeting and conferring regarding discovery, the parties have

16 agreed to stipulate to extend the deadline to submit their stipulated discovery plan
17 and scheduling order to forty-five (45) days after Ditech has filed an answer to the
18 SAC.
19

9.

Due to the changing nature of the pleadings, the possibility of further

20 dispositive motions that may narrow the issues in the case, and the parties’
21 willingness to cooperate on efforts to streamline discovery in this matter, good cause
22 exists to delay extend the deadline for the Parties to submit a proposed discovery
23 plan until after Ditech has responded to the SAC.
24

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11293.0677/8192332.1

2:16-cv-00783-APG-CWH
2
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

1

10.

This is the first stipulation for extension of the deadline to file a

2 proposed discovery plan.
3

IT IS SO STIPULATED.

4

DATED this 17th day of August, 2016.

5 KAZEROUNI LAW GROUP, APC

McDONALD CARANO WILSON LLP

6
7 ___/s/ Michael Kind___________
Michael Kind
8
Attorneys for Plaintiff
9

/s Laura R. Jacobsen________________
Laura R. Jacobsen
Attorneys for Defendant Green Tree
Servicing LLC, now known as Ditech
Financial LLC

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11
12

IT IS SO ORDERED.

13

August 19
DATED this ____ day of _____________, 2016

14
_________________________
United States Magistrate Judge

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11293.0677/8192332.1

2:16-cv-00783-APG-CWH
3
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT