Collier v. Experian Information Solutions, Inc. et al

Filing 19

ORDER Granting 18 Stipulation to Extend Deadline to Amend Pleadings. Signed by Magistrate Judge Peggy A. Leen on 8/7/17. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01486-APG-PAL Document 18 Filed 08/03/17 Page 1 of 4

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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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DRAKE COLLIER,

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Plaintiff,

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vs.

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

[First Request]

Defendants.

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STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES

EXPERIAN INFORMATION SOLUTIONS,
INC. and TRANS UNION, LLC,

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Case No. 2:17-cv-01486-APG-PAL

Pursuant to LR 6-1 and LR 26-4, Plaintiff, Experian Information Solutions, Inc.
(“Experian”), and Trans Union LLC (“Trans Union”), by and through their respective counsel of
record, hereby stipulate and request that this Court extend the motion to amend deadline by fifty
(50) days. At this time, the parties are not seeking an extension of any other discovery deadlines
but reserve the right to request in the future. In support of this Stipulation and Request, the parties
state as follows:
I.

DISCOVERY COMPLETED TO DATE
1.

Plaintiff filed the instant complaint on May 25, 2017.

2.

On June 21, 2017, Experian filed its answer.

3.

On June 29, 2017, Plaintiff and Experian held the Rule 26 conference.

4.

On July 5, 2017, Trans Union filed its answer.

Case 2:17-cv-01486-APG-PAL Document 18 Filed 08/03/17 Page 2 of 4

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5.

On June 29, 2017, Plaintiff served Experian with requests for admission, requests

for production of documents, and interrogatories.

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6.

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 8, 2017. Experian’s witness is not available

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on August 8, 2017, but is available on September 20, 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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7.

On July 13, 2017, the Discovery Plan and Scheduling Order was entered.

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8.

On July 18, 2017, the Stipulated Protective Order was entered.

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9.

On July 13, 2017, Trans Union and Experian served their initial disclosures.

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10.

On July 14, 2017, Plaintiff served his 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 20, 2017;

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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;

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3.

Depositions of remaining parties and witnesses; and,

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4.

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 18, 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 20, 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 9, 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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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

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Case 2:17-cv-01486-APG-PAL Document 18 Filed 08/03/17 Page 3 of 4

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

Proposed Discovery Deadlines

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Event
Close of Discovery

Current Deadline
December 18, 2017

Proposed New Deadline
Same

Deadline to Amend Pleadings

September 19, 2017

November 9, 2017

Deadline to Disclose Initial
Experts

October 19, 2017

Same

Deadline to Disclose Rebuttal
Experts

November 20, 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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Case 2:17-cv-01486-APG-PAL Document 18 Filed 08/03/17 Page 4 of 4

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Dispositive Motions

January 18, 2018

Same

Pre-Trial Order

February 19, 2018

Same

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Dated: August 3, 2017

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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.
LEWIS BRISBOIS BISGAARD & SMITH LLP

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By: /s/ Jason Revzin
Jason G. Revzin
Nevada Bar No. 8629
6385 S. Rainbow Blvd., Suite 600
Las Vegas, NV 89118

Attorneys for Plaintiff

Attorneys for Defendant Trans Union LLC

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ORDER

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IT IS SO ORDERED.

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Dated: August 7, 2017

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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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