Leoni v. Experian Information Solutions, Inc. et al

Filing 11

ORDER Granting 10 Stipulation to Extend Discovery Deadlines. If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order. Signed by Magistrate Judge Cam Ferenbach on 7/28/17. (Copies have been distributed pursuant to the NEF - ADR)

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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]
[e-mail]
Attorneys for Defendant
Experian Information Solutions, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DAVID LEONI,

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Plaintiff,

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Case No. 2:17-cv-01408-RFB-VCF

v.
EXPERIAN INFORMATION SOLUTIONS,
INC. and MILITARY STAR,

STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES
[First Request]

Defendants.

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Pursuant to LR 6-1 and LR 26-4, Plaintiff and Experian Information Solutions, Inc., by and

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through their respective counsel of record, hereby stipulate and request that this Court extend the

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motion to amend deadline by fifty (50) days. At this time, the parties are not seeking an extension

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of any other discovery deadlines but reserve the right to request in the future. In support of this

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Stipulation and Request, the parties state as follows:

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I.

DISCOVERY COMPLETED TO DATE

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Presently, the active parties to this case are Plaintiff and Experian Information Solutions,

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Inc. (“Experian”), and as such, the recitation of discovery shall be with respect to Plaintiff and

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Experian.

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1.

Plaintiff filed the instant complaint on May 18, 2017.

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2.

On June 12, 2017, Experian filed its answer.

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

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3.

On June 23, 2017, the parties held the Rule 26 Conference.

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4.

On June 23, 2017, Plaintiff served Experian with requests for admission, requests

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for production of documents, and interrogatories. Experian responded on July 24, 2017.

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5.

On June 23, 2017, Plaintiff served Experian with a notice of deposition, setting the

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deposition of Experian’s 30(b)(6) designee for August 1, 2017. Experian’s witness is not available

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on August 1, 2017, but is available on September 15, 2017. Plaintiff’s counsel has agreed to this

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date provided the parties stipulate to the extension of the motion to amend deadline until 50 days

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after the renoticed deposition date and Plaintiff’s deposition occurs after Experian’s deposition.

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6.

On July 5, 2017, the parties submitted a proposed Discovery Plan and Scheduling

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7.

On July 6, 2017, the Stipulated Protective Order was entered.

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8.

On July 25, 2017, Experian served its initial disclosures.

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9.

On July 26, 2017, Plaintiff served his initial disclosures.

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Order.

B.

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1.

The deposition of Experian’s 30(b)(6) witness, which Plaintiff has agreed to

renotice for September 15, 2017;

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Specific Description of Discovery that Remains to be Completed

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The deposition of Plaintiff, which Experian has agreed to renotice for a date after

Experian’s rescheduled deposition;

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3.

Depositions of remaining parties and witnesses; and,

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Any necessary additional written discovery.

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C.

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Reasons Why the Remaining Discovery Was Not Completed
The parties aver, pursuant to LR 6-1, that good cause exists for the requested extension.

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At this juncture, the discovery close is December 11, 2017.1

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discovery deadlines is made well in advance of the applicable discovery deadlines and is made to

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accommodate the availability of Experian’s 30(b)(6) designee on September 15, 2017, and

This stipulation to extend the

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

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Court.

This is based on the Proposed Discovery Plan (ECF No. 7), which stands submitted to the
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Plaintiff’s request, and the parties’ agreement, to extend the motion to amend pleadings deadline

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such that the motion to amend pleadings deadline will now be approximately fifty (50) days after

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Experian’s rescheduled deposition, or November 6, 2017. At this time, the parties do not request

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an extension of any other discovery deadlines, but only an extension of the motion to amend

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deadline. The parties reserve the right to seek an extension of other deadlines in the future.

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D.

Proposed Discovery Deadlines

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Event
Close of Discovery

Current Deadline2
December 11, 2017

Proposed New Deadline
Same

Deadline to Amend Pleadings

September 11, 2017

November 6, 2017

Deadline to Disclose Initial
Experts

October 10, 2017

Same

Deadline to Disclose Rebuttal
Experts

November 9, 2017

Same

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

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See n. 1.
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Dispositive Motions

January 8, 2018

Same

Pre-Trial Order

February 7, 2018

Same

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Dated: July 27, 2017

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NAYLOR & BRASTER

KNEPPER & CLARK, LLC

By: /s/ Jennifer L. Braster
Jennifer L. Braster (NBN 9982)
Nevada Bar No. 9982
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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If dispositive motions are filed, the deadline
for filing the joint pretrial order will be
suspended until 30 days after
decision on the dispositive motions or further
court order.

Attorneys for Plaintiff

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ORDER

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IT IS SO ORDERED.
July 28, 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]

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