Lee C. Kamimura v. Green Tree Services, LLC

Filing 52

ORDER Granting 51 Stipulation to Extend Deadlines. IT IS HEREBY ORDERED that the deadlines for Plaintiff to file his motion for class certification will be 3/7/18 and the deadline to file dispositive motions will be 4/9/18. Signed by Magistrate Judge Carl W. Hoffman on 2/27/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-00783-APG-CWH Document 51 Filed 02/22/18 Page 1 of 4

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Michael Kind, Esq.
Nevada Bar No. 13903
KAZEROUNI LAW GROUP, APC
6069 South Fort Apache Road, Suite 100
Las Vegas, Nevada 89148
Phone: [phone] x7
[e-mail]
David H. Krieger, Esq. (SBN: 9086)
HAINES & KRIEGER, LLC
8985 S. Eastern Avenue, Suite 350
Henderson, NV 89123
Phone: [phone]
FAX: [phone]
[e-mail]
Attorneys for Plaintiff Lee C. Kamimura
individually and on behalf of others similarly situated

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Lee C. Kamimura, individually
and on behalf of all others
similarly situated,
Plaintiff,
v.
Ditech Financial LLC, fka Green
Tree Services LLC,

Case No.: 2:16-cv-00783-APG-CWH
Joint Stipulation and Order to
Extend the deadline to file
dispositive motions and Plaintiff’s
motion for class certification
(Sixth Request)

Defendant.

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11293.0677/11098146.1

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STIPULATION TO EXTEND DISCOVERY
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CASE NO.: 2:16-cv-00783-APG-CWH

Case 2:16-cv-00783-APG-CWH Document 51 Filed 02/22/18 Page 2 of 4

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Plaintiff Lee C. Kamimura (“Plaintiff”) and Defendant Ditech Financial LLC,

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fka Green Tree Services LLC (“Defendant” and together with Plaintiff, the

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“Parties”) by and through their counsel of record hereby stipulate to extend the

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motions deadline in this case as follows:

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(1) The deadline for Plaintiff to file his motion for class certification will be
March 7, 2018.
(2) The deadline to file dispositive motions will be April 9, 2018.

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The current deadline to file dispositive motions is February 28, 2018. ECF

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No. 44. Since this Court’s October 3, 2017 scheduling order, ECF No. 44, this

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Court granted two additional stipulations by the parties to extend the discovery

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cutoff. ECF Nos. 46, 48.

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Good cause exists to amend the Scheduling Order. The parties took each

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others’ experts depositions on February 8-9, 2018. The parties are still waiting for

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deposition transcripts to become available. Discovery is closed and the Parties do

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not seek any additional discovery, other than the discovery dispute raised in

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Plaintiff’s motion to compel discovery. ECF No. 29.

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The Parties are also continuing to actively discuss an informal resolution to
this matter.
Pursuant to LR 26-4(a), the Parties have propounded written discovery
requests on each other, have taken each others’ depositions and expert depositions.

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Pursuant to LR 26-4(b), the Parties request additional time to receive, read

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and sign, expert deposition transcripts and file dispositive motions in this case and

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for Plaintiff to file his class certification motion.

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Plaintiff anticipates filing his motion for class certification and a motion for

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summary judgment on or before March 7, 2018. The parties request a 45-day

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extension to file their dispositive motions.

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Pursuant to LR 26-4(d), the Parties respectfully propose the following
briefing schedule:
11293.0677/11098146.1

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STIPULATION TO EXTEND DISCOVERY
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CASE NO.: 2:16-cv-00783-APG-CWH

Case 2:16-cv-00783-APG-CWH Document 51 Filed 02/22/18 Page 3 of 4

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(1) The deadline for Plaintiff to file his motion for class certification will be
March 7, 2018.
(2) The deadline to file dispositive motions will be April 9, 2018.
This is the Parties’ sixth request for an extension of these deadlines.
DATED this 22nd day of February 2018.
KAZEROUNI LAW GROUP, APC

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

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SEVERSON & WERSON

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By: /s/ Mary Kate Kamka
Donald H. Cram, Esq.
Laszlo Ladi, Esq.
Mary Kate Kamka, Esq.
One Embarcadero Center, Suite 2600
San Francisco, California 94111
Attorneys for Defendant Ditech Financial LLC
formerly known as Green Tree Servicing LLC

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ORDER
IT IS HEREBY ORDERED that:
(1) The deadline for Plaintiff to file his motion for class certification will be
March 7, 2018, and
(2) The deadline to file dispositive motions will be April 9, 2018.

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IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE

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Dated:

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February 27, 2018

11293.0677/11098146.1

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STIPULATION TO EXTEND DISCOVERY
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CASE NO.: 2:16-cv-00783-APG-CWH

Case 2:16-cv-00783-APG-CWH Document 51 Filed 02/22/18 Page 4 of 4

CERTIFICATE OF SERVICE

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I HEREBY CERTIFY pursuant to Rule 5 of the Federal Rules of Civil

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Procedure that on February 22, 2018, the foregoing Stipulation was filed and served

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via CM/ECF to all parties appearing in this case.

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KAZEROUNI LAW GROUP, APC

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By: /s/ Michael Kind
Michael Kind
6069 South Fort Apache Road, Suite 100
Las Vegas, Nevada 89148

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11293.0677/11098146.1

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STIPULATION TO EXTEND DISCOVERY
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CASE NO.: 2:16-cv-00783-APG-CWH