Del Rivero v. Portfolio Recovery Associates, LLC et al

Filing 25

ORDER Granting 23 Stipulation re Discovery Deadlines. Discovery due by 3/19/2018. Motions due by 4/13/2018. Proposed Joint Pretrial Order due by 5/14/2018. Signed by Magistrate Judge Carl W. Hoffman on 12/20/2017. (Copies have been distributed pursuant to the NEF - MMM)

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1 2 3 4 5 6 ROBERT S. LARSEN, ESQ. Nevada Bar No. 7785 WING YAN WONG, ESQ. Nevada Bar No. 13622 GORDON REES SCULLY MANSIKHANI, LLP 300 South Fourth Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Direct: (702) 577-9310 Facsimile: (702) 255-2858 E-Mail: rlarsen@grsm.com wwong@grsm.com 7 Attorneys for Portfolio Recovery Associates, LLC 8 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 300 S. 4th Street, Suite 1550 Las Vegas, NV 89101 Gordon Rees Scully Mansukhani, LLP 9 12 13 14 15 16 17 18 JAVIER DEL RIVERO, ) ) Plaintiff, ) ) vs. ) ) ) PORTFOLIO RECOVERY ASSOCIATES, LLC, a ) foreign limited liability company; and EXPERIAN ) INFORMATION SOLUTIONS, INC., ) ) Defendants. ) ) Case No.: 2:17-cv-01606-JAD-CWH STIPULATION AND ORDER TO AMEND SCHEDULING ORDER [ECF NO. 19] (First Request) Pursuant to Fed. R. Civ. P. 16(b)(4), LR IA 6-1, and LR 26-4, Plaintiff Javier Del Rivero; 19 Defendant Portfolio Recovery Associates, LLC (“PRA); and Defendant Experian Information 20 Solutions, Inc. (“Experian”) (collectively, the “Parties”), by and through their respective counsel 21 of record, hereby stipulate to amend the Amended Scheduling Order entered on September 5, 22 2017, ECF No. 19. 23 The Parties seek to extend the discovery cut-off by sixty (60) days. The current 24 discovery cut-off is January 16, 2018. See ECF No. 19. The Parties request to extend this 25 deadline to March 19, 2018. In addition, the Parties request that the dispositive motions and 26 pretrial order deadlines be extended for an additional sixty (60) days, or until April 13, 2018 27 (dispositive motions) and May 14, 2018 (pretrial order). 28 -1- 1 I. 2 Discovery Completed To date, the Parties have completed the following discovery: the Parties have each 3 served initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1); PRA propounded Requests for 4 Production and Interrogatories on Plaintiff; Experian propounded Request for Production, 5 Interrogatories, and Requests for Admission on Plaintiff; and Plaintiff propounded Request for 6 Production, Interrogatories, and Requests for Admission upon both PRA and Experian. All 7 parties have served responses to these requests. 8 II. 9 Discovery That Remains to be Completed The Parties still need to conduct the deposition of Plaintiff, previously scheduled for December 18, 2017, and to complete any discovery allowed by the Court’s disposition of PRA’s 11 300 S. 4th Street, Suite 1550 Las Vegas, NV 89101 Gordon Rees Scully Mansukhani, LLP 10 Motion to Compel Production of Documents and Responses to Interrogatories and Requests for 12 Production and for Sanctions, ECF No. 22 (“Motion to Compel”), which is pending. 13 III. 14 Reasons Why Discovery Was Not Completed Here, good cause exists to extend the discovery cut-off. On December 12, 2017, PRA 15 filed the Motion to Compel. In the Motion to Compel, PRA seeks the Court’s assistance to 16 compel Plaintiff’s responses to PRA’s Requests for Production and Interrogatories. PRA 17 anticipates the briefing on the Motion to Compel will be complete on or about January 2, 2018. 18 The deposition of Plaintiff was previously scheduled for December 18, 2017. The Parties agreed 19 to postpone the deposition of Plaintiff to allow the Court to first address the Motion to Compel. 20 Therefore, the Parties seek a brief extension of the discovery cut-off for the Court to first resolve 21 the Motion to Compel and for the deposition of Plaintiff to proceed thereafter. 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// -2- 1 2 3 4 5 IV. Proposed Schedule to Complete Remaining Discovery Event Current Deadline Proposed New Deadline Close of Discovery January 16, 2018 March 19, 2018 Dispositive Motions February 12, 2018 April 13, 2018 Pre-Trial Order March 14, 2018 May 14, 2018 6 7 8 9 11 300 S. 4th Street, Suite 1550 Las Vegas, NV 89101 Gordon Rees Scully Mansukhani, LLP 10 12 13 14 Dated this 19th date of December, 2017 Dated this 19th date of December, 2017 /s/ Wing Yan Wong Robert S. Larsen, Esq. Nevada Bar No. 7785 Wing Yan Wong, Esq. Nevada Bar No. 13622 Gordon Rees Scully Mansukhani, LLP 300 South Fourth Street, Suite 1559 Las Vegas, NV 89101 /s/ Jennifer L. Braster Jennifer L. Braster, Esq. Nevada Bar No. 9982 Naylor & Braster 1050 Indigo Drive, Suite 200 Las Vegas, NV 89145 Andrew M. Cummings, Esq. Nevada Bar No. 14505 Attorneys for Portfolio Recovery Associates, Jones Day LLC 3161 Michelson Dr., Suite 800 Irvine, CA 92612-4408 Attorneys for Defendant Experian Information Solutions, Inc. 15 16 Dated this 19th date of December, 2017 17 18 19 20 21 22 /s/ Melissa Ingleby Vernon A. Nelson, Esq. Nevada Bar No. 6434 Melissa Ingleby, Esq. Nevada Bar No. 12935 The Law Office of Vernon Nelson 9480 S. Eastern Avenue, Suite 252 Las Vegas, NV 89123 Attorney Plaintiff Javier Del Rivero 23 24 25 IT IS SO ORDERED: ______________________________ 26 27 1139930/36046839v.1 UNITED STATES MAGISTRATE JUDGE 28 DATED: 12/20/17 -3-

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