Polangcus v. Experian Information Solutions, Inc.
Filing
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ORDER Granting 12 Stipulation for Extension of Time re Discovery Deadlines (First Request). Signed by Magistrate Judge Carl W. Hoffman on 8/7/17. (Copies have been distributed pursuant to the NEF - MR)
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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) (702) 420-7000
(F) (702) 420-7001
jbraster@naylorandbrasterlaw.com
asharples@naylorandbrasterlaw.com
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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HERA POLANGCUS,
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Plaintiff,
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v.
EXPERIAN INFORMATION SOLUTIONS,
INC,
Case No. 2:17-cv-01477-JAD-CWH
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.
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(“Experian”), by and through their respective counsel of record, hereby stipulate and request that
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this Court extend the motion to amend deadline by fifty (50) days. At this time, the parties are not
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seeking an extension of any other discovery deadlines but reserve the right to request in the future.
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In support of this Stipulation and Request, the parties state as follows:
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I.
DISCOVERY COMPLETED TO DATE
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1.
Plaintiff filed the instant complaint on May 24, 2017.
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2.
On June 15, 2017, Experian filed its answer.
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3.
On June 29, 2017, Plaintiff and Experian held the Rule 26 conference.
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4.
On June 29, 2017, Plaintiff served Experian with requests for admission, requests
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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
(702) 420-7000
for production of documents, and interrogatories, which Experian responded to on July 31, 2017.
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5.
On June 29, 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 9, 2017. Experian’s witness is not available
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on August 9, 2017, but is available on September 12, 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 7, 2017, the Discovery Plan and Scheduling Order was entered.
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7.
On July 7, 2017, the Stipulated Protective Order was entered.
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8.
On July 13, 2017, Experian served its initial disclosures.
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9.
On July 14, 2017, Plaintiff served her initial disclosures.
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B.
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1.
The deposition of Experian’s 30(b)(6) witness, which Plaintiff has agreed to
renotice for September 12, 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.
Reasons Why the Remaining Discovery Was Not Completed
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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 12, 2017. This stipulation to extend the discovery
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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 12, 2017, and
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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 1, 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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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
(702) 420-7000
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D.
Proposed Discovery Deadlines
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Event
Close of Discovery
Current Deadline
December 12, 2017
Proposed New Deadline
Same
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Deadline to Amend Pleadings
September 13, 2017
November 1, 2017
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Deadline to Disclose Initial
Experts
October 13, 2017
Same
Deadline to Disclose Rebuttal
Experts
November 13, 2017
Same
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Dispositive Motions
January 11, 2018
Same
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Pre-Trial Order
February 12, 2018
Same
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Dated: August 4, 2017
NAYLOR & BRASTER
KNEPPER & CLARK, LLC
By: /s/ Jennifer L. Braster
Jennifer L. Braster
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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Attorneys for Plaintiff
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ORDER
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IT IS SO ORDERED.
August 7, 2017
Dated: __________, _____
UNITED STATES MAGISTRATE JUDGE
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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
(702) 420-7000
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