Polangcus v. Experian Information Solutions, Inc.

Filing 13

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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1 2 3 4 5 6 7 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. 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 HERA POLANGCUS, 12 Plaintiff, 13 14 15 v. EXPERIAN INFORMATION SOLUTIONS, INC, Case No. 2:17-cv-01477-JAD-CWH STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES [First Request] Defendants. 16 17 Pursuant to LR 6-1 and LR 26-4, Plaintiff and Experian Information Solutions, Inc. 18 (“Experian”), by and through their respective counsel of record, hereby stipulate and request that 19 this Court extend the motion to amend deadline by fifty (50) days. At this time, the parties are not 20 seeking an extension of any other discovery deadlines but reserve the right to request in the future. 21 In support of this Stipulation and Request, the parties state as follows: 22 I. DISCOVERY COMPLETED TO DATE 23 1. Plaintiff filed the instant complaint on May 24, 2017. 24 2. On June 15, 2017, Experian filed its answer. 25 3. On June 29, 2017, Plaintiff and Experian held the Rule 26 conference. 26 4. On June 29, 2017, Plaintiff served Experian with requests for admission, requests 27 28 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. 1 5. On June 29, 2017, Plaintiff served Experian with a notice of deposition, setting the 2 deposition of Experian’s 30(b)(6) designee for August 9, 2017. Experian’s witness is not available 3 on August 9, 2017, but is available on September 12, 2017. Plaintiff’s counsel has agreed to this 4 date provided the parties stipulate to the extension of the motion to amend deadline until 50 days 5 after the renoticed deposition date and Plaintiff’s deposition occurs after Experian’s deposition. 6 6. On July 7, 2017, the Discovery Plan and Scheduling Order was entered. 7 7. On July 7, 2017, the Stipulated Protective Order was entered. 8 8. On July 13, 2017, Experian served its initial disclosures. 9 9. On July 14, 2017, Plaintiff served her initial disclosures. 10 B. 11 12 1. The deposition of Experian’s 30(b)(6) witness, which Plaintiff has agreed to renotice for September 12, 2017; 13 14 Specific Description of Discovery that Remains to be Completed 2. The deposition of Plaintiff, which Experian has agreed to renotice for a date after Experian’s rescheduled deposition; 15 3. Depositions of remaining parties and witnesses; and, 16 4. Any necessary additional written discovery. 17 C. Reasons Why the Remaining Discovery Was Not Completed 18 The parties aver, pursuant to LR 6-1, that good cause exists for the requested extension. 19 At this juncture, the discovery close is December 12, 2017. This stipulation to extend the discovery 20 deadlines is made well in advance of the applicable discovery deadlines and is made to 21 accommodate the availability of Experian’s 30(b)(6) designee on September 12, 2017, and 22 Plaintiff’s request, and the parties’ agreement, to extend the motion to amend pleadings deadline 23 such that the motion to amend pleadings deadline will now be approximately fifty (50) days after 24 Experian’s rescheduled deposition, or November 1, 2017. At this time, the parties do not request 25 an extension of any other discovery deadlines, but only an extension of the motion to amend 26 deadline. The parties reserve the right to seek an extension of other deadlines in the future. 27 28 NAYLOR & BRASTER ATTORNEYS AT LAW 1050 Indigo Drive, Suite 200 Las Vegas, NV 89145 (702) 420-7000 2 of 3 1 2 D. Proposed Discovery Deadlines 3 Event Close of Discovery Current Deadline December 12, 2017 Proposed New Deadline Same 4 Deadline to Amend Pleadings September 13, 2017 November 1, 2017 5 Deadline to Disclose Initial Experts October 13, 2017 Same Deadline to Disclose Rebuttal Experts November 13, 2017 Same 7 8 Dispositive Motions January 11, 2018 Same 9 Pre-Trial Order February 12, 2018 Same 6 10 11 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 12 13 14 15 16 17 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. 18 19 Attorneys for Plaintiff 20 ORDER 21 22 23 24 IT IS SO ORDERED. August 7, 2017 Dated: __________, _____ UNITED STATES MAGISTRATE JUDGE 25 26 27 28 NAYLOR & BRASTER ATTORNEYS AT LAW 1050 Indigo Drive, Suite 200 Las Vegas, NV 89145 (702) 420-7000 3 of 3

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