Goodman v. M&T Bank, National Association et al

Filing 53

ORDER Granting 52 Third Stipulation to Extend Post-Discovery Deadlines. Signed by Magistrate Judge Carl W. Hoffman on 6/16/2017. (Copies have been distributed pursuant to the NEF - SLD)

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Jennifer L. Braster
Nevada Bar No. 9982
Andrew J. Sharples
Nevada Bar No. 12866
NAYLOR & BRASTER
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
(T) [phone]
(F) [phone]
[e-mail]
Attorneys for Defendant
Experian Information Solutions, Inc.
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SERENA J. GOODMAN,

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Plaintiff,

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v.

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M&T BANK, NATIONAL ASSOCIATION;
AMERASSIST AR SOLUTIONS, INC;
FARMERS INSURANCE FEDERAL
CREDIT UNION; ALLSTATE
INSURANCE, CO; EQUIFAX
INFORMATION SERVICES, LLC;
EXPERIAN INFORMATION SOLUTIONS,
INC,

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Case No. 2:16-cv-01799-APG-CWH

STIPULATION AND ORDER TO EXTEND
POST-DISCOVERY DEADLINES

Complaint filed: July 28, 2016

Defendants.

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COMES NOW the parties, by and through their undersigned counsel of record, hereby
stipulate and agree as follows:
1.

On May 19, 2017, Plaintiff Serena J. Goodman (“Plaintiff”) filed her Motion for

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Leave to File First Amended and Supplemental Complaint (the “Motion to Amend”) (ECF No.

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45), seeking, among other things, to amend her complaint to assert potential class allegations.

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2.

On June 2, 2017, Defendant Experian Information Solutions, Inc. (“Experian”)

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filed its Opposition to Plaintiff’s Motion for Leave to File First Amended and Supplemental

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Complaint (ECF No. 47) and Defendant M&T Bank (“M&T”) filed its Opposition to Motion to

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42023765.1

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File First Amended and Supplemental Complaint, or, Alternatively, Motion to Sever (ECF No.

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460.

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3.

Briefing on Plaintiff’s Motion to Amend and M&T’s Motion to Sever is still

underway.
4.

Currently, the dispositive motion deadline is July 5, 2017. The parties agree that to

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prevent the incurrence of unnecessary attorneys’ fees, costs, and to conserve judicial resources,

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the deadline for filing dispositive motions shall be 30 days after the Court rules on the Motion to

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Amend and M&T’s Motion to Sever, or some later date should there be a further stipulation or

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order from the Court. The deadline for filing a pretrial order shall be 30 days after the dispositive

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motion deadline. This is the parties’ third request for an extension of the dispositive motion and

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pretrial order deadlines, and is only being requested to avoid unnecessary briefing in light of the

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pending Motion to Amend and M&T’s Motion to Sever.

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5.

This stipulation is without prejudice to the arguments and positions taken by the

parties in their respective briefing relating to the Motion to Amend and M&T’s Motion to Sever.
6.

Additionally, M&T and Plaintiff are engaging in meet and confer regarding

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whether the deposition testimony provided by M&T on June 1, 2017 adequately addressed all

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topics. Plaintiff and M&T believe it appropriate to obtain a copy of the deposition transcript in

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order to meaningfully complete those discussions. The parties anticipate the transcript will be

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ready on or about June 21, and the parties will meet and confer within approximately one week

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thereafter. If there is to be a supplemental production by M&T, the parties will alert the court

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through a status report. If not, Plaintiff will have 21 days from the conclusion of the meet and

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confer to file any necessary motion in connection with this meet and confer relating to M&T,

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which will be treated as timely despite being after the close of discovery. To the extent the

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dispositive motion deadline is not stayed as set forth in paragraph 4 above, the parties agree and

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request that the dispositive motion deadline be extended 75 days to accommodate the discussions

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set forth in this paragraph, without prejudice for an additional extension if motion practice is

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required.

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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

42023765.1

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7.

This stipulation is without prejudice for any party to seek additional relief, and any

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party may file a dispositive motion irrespective of the stay or extension of the deadline for

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dispositive motions herein.

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Dated: June 16, 2017

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NAYLOR & BRASTER

KNEPPER & CLARK LLC

By: /s/ Jennifer L. Braster
Jennifer L. Braster
Nevada Bar No. 9982
Andrew J. Sharples
Nevada Bar No. 12866
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145

By: /s/ Miles N. Clark
Matthew I. Knepper (NBN 12796)
Miles N. Clark (NBN 13848)
10040 W. Cheyenne Ave., Suite 170-109
Las Vegas, NV 89129

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David H. Krieger
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
8985 S. Eastern Avenue, Suite 350
Henderson, NV 89123

Attorneys for Defendant Experian
Information Solutions, Inc.

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Attorneys for Plaintiff

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AKERMAN LLP
By: /s/ Rex D. Garner
Darren T. Brenner (NBN 8386)
Rex D. Garner (NBN 9401)
Natalie L. Winslow (NBN 12125)
1160 Town Center Drive, Suite 330
Las Vegas, Nevada 89144
Attorneys for M&T Bank, National
Association
ORDER
IT IS SO ORDERED.
June 16, 2017
Dated: __________, _____

UNITED STATES MAGISTRATE JUDGE

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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

42023765.1