Brown v Credit One Bank, N.A.

Filing 37

ORDER Granting 36 Stipulation re Discovery Deadlines. Discovery due by 10/4/2018. Motions due by 11/5/2018. Proposed Joint Pretrial Order due by 12/4/2018. Signed by Magistrate Judge Cam Ferenbach on 1/23/2018. (Copies have been distributed pursuant to the NEF - MMM)

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Mark Ankcorn
California Bar No. 166871
Admitted Pro Hac Vice
Ann Marie Hansen
Nevada Bar No. 10144
ANKCORN LAW FIRM, PC
1060 Woodcock Road, Suite 128
Orlando, Florida
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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Michael Kind, Esq.
Nevada Bar No. 13903
KAZEROUNI LAW GROUP, APC
7854 West Sahara Avenue
Las Vegas, Nevada 89117
Phone: [phone] ext. 7
Fax: [phone]
Local Counsel for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Jewell Bates Brown, an individual,
Plaintiff,

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Case No. 2:17-cv-00786-JAD-VCF

v.

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Credit One Bank, N.A.,

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STIPULATION AND ORDER
TO EXTEND DISCOVERY
DEADLINES (FIRST
REQUEST)

Defendant.

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Credit One Bank, N.A. (“Credit One”) and Jewell Bates Brown (“Plaintiff”) request
that the Court extend the current discovery deadlines in this case by 180 days.

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Discovery Completed To Date:
Plaintiff served written discovery requests on Credit One on August 8, 2017. Credit

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One responded on September 13, 2017. Plaintiff seeks further responses, but Credit

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One has objected to further responses pending the Court's ruling on the Motion to

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Compel Arbitration [Dkt. 23] and Motion to Dismiss or Stay [Dkt 24 and 25] that Credit

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One filed on September 11, 2017. Said motions are fully briefed.

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Discovery that Remains To Be Completed:
Plaintiff intends to file a motion to compel substantive responses to the written
discovery requests. Plaintiff also plans to conduct the 30(b)(6) deposition of Credit One

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after obtaining substantive responses to the written discovery. And, Plaintiff intends to

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disclose an expert.

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Subject to the Court's ruling on the pending motions, Credit One may serve written
discovery, take relevant depositions, and disclose a rebuttal expert.
Reason Why Discovery Not Completed:
Credit One has objected to proceeding further in discovery until there is a ruling on

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the pending Motion to Compel Arbitration and Motion to Dismiss or Stay. In the

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meantime, Credit One has responded to relevant written discovery requests as a

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measure of good faith and produced relevant documents pertaining to the pending

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motions. As mentioned previously, Plaintiff intends to file a motion to compel further

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discovery responses. In addition, Plaintiff’s counsel, Mr. Ankcorn, is experiencing

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severe medical issues with his immediate family right now that are very time
consuming. Accordingly, good cause exists to extend the current discovery deadlines for

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180 days.

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Proposed Schedule for Completing Discovery:
a. Discovery Cut-Off Date: October 4, 2018

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b. Expert Report Deadline: August 6, 2018

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c. Rebuttal Expert Report Deadline: September 7, 2018

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d. Deadline for Amending Pleadings/Adding Additional Parties:

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July 5, 2018

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e. Dispositive Motion Deadline: November 5, 2018

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f. Interim Status Report: August 2, 2018

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g. Joint Pre-trial Order: December 4, 2018, or in the event that a

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summary judgment or adjudication motion is filed, the date for

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filing the joint pretrial order shall be suspended until 30 days after

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decision on the summary judgment or adjudication motion or until

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further order of the court.

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h. Pretrial Disclosures: The disclosures required by Fed. R. Civ. P.

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26(a)(3), and any objections thereto, shall be included in the joint

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pretrial order.

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IT IS SO STIPULATED.

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Dated:

January 17, 2018

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/s/ Ann Marie Hansen
Attorney for Plaintiff

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Dated:

January 17, 2018

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/s/ Tuan Uong
Attorney for Defendant

IT IS SO ORDERED.
________________________________
United States Magistrate Judge
1-23-2018

Dated: _________________________