Lee C. Kamimura v. Green Tree Services, LLC

Filing 48

ORDER Granting 47 Stipulation to Extend Discovery Deadline. Discovery due by 2/21/2018. Signed by Magistrate Judge Carl W. Hoffman on 1/23/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-00783-APG-CWH Document 47 Filed 01/22/18 Page 1 of 4

1 LAURA R. JACOBSEN
NV BAR NO. 13699
2 McDONALD CARANO LLP
100 W. Liberty St., 10th Floor
3 P.O. Box 2670
Reno, Nevada 89505
4 Telephone: [phone]
Facsimi le: (775) 788-202
5 [e-mail]
6 JOHN B. SULLIVAN (CA Bar No. 96742)
DONALD H. CRAM (CA Bar No. 160004 )
7 dhc(a),severson.corn
MARY KATE KAMKA (CA Bar No. 282911)
8 mkk(a),severson.com
LASZLO LADT(CA Bar No. 265564)
9 ll @severson.com
SfNERSON & WERSON
1O A Profess ional Corporation
One Embarcadero Center, Suite 2600
11 San Francisco, Californ ia 94111
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for Defendant
Ditech Financial LLC
14 f 9rmerly_ known as
Green Tree Servicing LLC
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEV ADA

18 Lee C. Kamimura, indiv idually and all
others similarly situated,
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Plaintiff,
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vs.
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Ditech Financial LLC formally known
22 as Green Tree Servicing, LLC,
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Case No. 2: 16-cv-00783-APG-CWH

JOINT STIPULATION AND
ORDER TO EXTEND DISCOVERY
DEADLINE
(FIFTH REQUEST)

Defendant.

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Plaintiff Lee C. Kamimura ("Plaintiff') and Defendant Ditech Financial LLC,

26 formally known as Green Tree Services LLC ("Defendant" and together with
27 Plaintiff, the "Parties") by and through their counsel of record hereby stipulate to
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I 1293.0677/1 I 056933 . I

2: 16-cv-00783-APG-CW!-1
JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

Case 2:16-cv-00783-APG-CWH Document 47 Filed 01/22/18 Page 2 of 4

1 modify the Court's December 19, 2017 Order, ECF No. 46, to extend:
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( 1) The deadline to complete Phase Two discovery from January 31, 2018 to
February 21, 2018.

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Pursuant to LR 26-4, the parties agree that good cause exists to amend the

5 Scheduling Order. The request is made due to an unforeseen delay in the deposition
6 of Defendant's expert John Ulzheimer. Due to inclement weather conditions in
7 Atlanta, the deposition needed to be postponed. The parties have rescheduled John
8 Ulzheimer's deposition to February 8, 2018. The parties have further agreed to
9 complete Plaintiffs expert's deposition by February 21, 2018. Further good cause
10 exists because the Parties continue to actively discussing resolution of this case and
11 certain discovery disputes. The Parties therefore require additional time in order to
12 complete expert discovery and to continue to meet and confer and discuss
13 resolution. The discovery extension is jointly requested by the Parties in good faith.
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Pursuant to LR 26-4(a), the Parties have propounded written discovery

15 requests on each other and taken all necessary depositions, apart from the parties'
16 expert's depositions.
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Pursuant to LR 26-4(a), the Parties need to conduct the depositions of both

18 parties' experts.
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11293.06 77 /11056933.1

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JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

Case 2:16-cv-00783-APG-CWH Document 47 Filed 01/22/18 Page 3 of 4

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Pursuant to LR 26-4( d), the Parties propose the following discovery schedule:

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(1) The deadline to complete Phase Two discovery will be February 21, 2018.

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For these reasons, the Parties jointly request that this Comi modify the August

4 December 19, 2017 Order to provide an additional 21 days to complete discovery.

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This is the Parties' fifth request for an extension of the discovery deadline.

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DATED this 22nd day of January, 2018

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KAZEROUNI LAW GROUP, APC

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By ls/Michael Kind
Michael Kind, Esq.
6069 South Fort Apache Road, Suite 100
Las Vegas, Nevada 89148
Attorneys for Plaintiff

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DATED this 22nd day of January, 2018

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MCDONALD CARANO LLP

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By ls/Laura R. Jacobsen
Laura R. Jacobsen, Esq.
100 W. Liberty St., 10th Floor
P.O. Box 2670
Reno, Nevada 89505

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Attorneys for Defendant
Ditech Financial LLC formerly known as
Green Tree Servicing LLC

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11293.0677/11056933.1

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JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

Case 2:16-cv-00783-APG-CWH Document 47 Filed 01/22/18 Page 4 of 4

DATED this 22nd day of January, 2018

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SEVERSON & WERSON
A Professional Corporation

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By Isl Donald H. Cram
Donald H. Cram
Laszlo Ladi
One Embarcadero Center, Suite 2600
San Francisco, California 94111
Tel. [phone]

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Attorneys for Defendant
Ditech Financial LLC formerly known as
Green Tree Servicing LLC

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ORDER

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IT IS HEREBY ORDERED that the December 19, 2017 Order, ECF No . 46,

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15 is modified to extend the discovery deadline as follows :
(1) The deadline to complete Phase Two discovery shall be February 21,

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17 2018.

Dated: January 23, 2018

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IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE

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11293.0677/11056933.1

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2: 16-cv-00783-APG-CWI-I
JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES