Mott v. Trinity Financial Services, LLC et al

Filing 26

ORDER granting 25 Stipulation; Discovery due by 7/11/2018. Motions due by 8/10/2018. Proposed Joint Pretrial Order due by 9/10/2018. Signed by Magistrate Judge George Foley, Jr on 5/29/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01754-RFB-GWF Document 25 Filed 05/25/18 Page 1 of 4

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Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
KNEPPER & CLARK LLC
10040 W. Cheyenne Ave., Suite 170-109
Las Vegas, NV 89129
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]
David H. Krieger, Esq.
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
8985 S. Eastern Ave., Suite 350
Henderson, NV 89123
Phone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RODNEY MOTT,

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Plaintiff,
vs.

STIPULATION FOR EXTENSION OF
TIME

TRINITY FINANCIAL SERVICES, LLC; and
TRINITY RECOVERY SERVICES, LLC,

(SECOND REQUEST)

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Case No.: 2:17-cv-01754-RFB-GWF

Defendants.
Pursuant to LR 6-1 and LR 26-4, Plaintiff and Defendants Trinity Financial Services,
LLC and Trinity Recovery Services, LLC (collectively, “Defendants”), by and through their
respective counsel of record, hereby stipulate and request that this Court extend the discovery
deadline by thirty (30) days. At this time, the parties are not seeking an extension of any other
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Case 2:17-cv-01754-RFB-GWF Document 25 Filed 05/25/18 Page 2 of 4

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discovery deadlines but reserve the right to request in the future depending on adjudication of
Plaintiff’s Motion for Leave to Amend, ECF Dkt. 8. In support of this Stipulation and Request,
the parties state as follows:
I.

1.

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On September 18, 2017, Plaintiff moved for leave to amend his complaint. ECF

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On September 15, 2018, Plaintiff served his Initial Disclosures.

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On August 4, 2017, Defendants filed their answers. ECF Dkt. 4, 5.

3.

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Plaintiff filed the instant complaint on June 26, 2017. ECF Dkt. 1.

2.

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DISCOVERY COMPLETED TO DATE

On September 28, 2017, the Court granted the parties’ stipulated protective order.

Dkt. 8.

ECF Dkt. 11.
6.

On October 10, 2017, the Court granted the parties’ stipulated discovery plan and

scheduling order. ECF Dkt. 17.
7.

On October 13, 2017, Plaintiff propounded his First Set of Requests for

Production and Interrogatories on Defendants.
8.

On November 17, 2017, Defendants responded to Plaintiff’s First Set of Requests

for Production and Interrogatories.

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9.

On December 9, 2017, Plaintiff served his First Supplemental Disclosures.

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10.

On December 12, 2017, the parties conducted a Rule 26-7 conference regarding

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Defendants’ responses to Plaintiff’s First Set of Requests for Production and Interrogatories.
11.

On January 25, 2018, Defendants provided their First Supplemental Responses to

Plaintiff’s First Set of Requests for Production and Interrogatories.
12.

On February 9, 2018, the parties submitted an interim status report. ECF Dkt. 22.

13.

On March 20, 2018, Plaintiff propounded his Notice of Deposition on Defendants,

setting the date of the depositions of both defendants for April 9, 2018.
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Case 2:17-cv-01754-RFB-GWF Document 25 Filed 05/25/18 Page 3 of 4

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14.
15.

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On May 15, 2018, Plaintiff propounded his Second Notice of Deposition on

Defendants, setting the date of the depositions of both defendants for June 4, 2018.
16.

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On March 22, 2018, Plaintiff served his Second Supplemental Disclosures.

On May 16, 2018, Plaintiff propounded deposition subpoenas and subpoenas for

records on third parties Corelogic Credco, DBI Co-Investor Fund VII, LLC, Dreambuilder
Investments, LLC, Land Home Financial Services, Ophrys, LLC, Stelis, LLC, Experian
Information Solutions, Inc., and Trans Union, LLC.
B.

Specific Description of Discovery that Remains to be Completed

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1.

The depositions of Defendants;

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2.

Depositions and discovery to any third party witnesses; and,

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3.

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 and excusable neglect exists for the

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requested extension. Plaintiff has set the deposition of Defendants’ person most knowledgeable

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for June 4, 2018.

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representative will be recovering from a medical procedure in early June and likely will be

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unavailable to sit for his deposition on the chosen date and time. Prior to notification, the parties

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had no indication that Defendant’s representative would not be in a position to sit for his

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deposition. A 30-day extension will permit Defendant’s representative sufficient time to

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//

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However, earlier this week the parties were advised that Defendants’

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convalesce and to arrange the deposition for a date thereafter.
D.
Proposed Discovery Deadlines
Event
Close of Discovery
Deadline to Amend Pleadings
Deadline to Disclose Initial
Experts
Deadline to Disclose Rebuttal
Experts
Dispositive Motions
Pre-Trial Order

Current Deadline
June 11, 2018
January 11, 2018
February 12, 2018

Proposed New Deadline
July 11, 2018
Same
Same

March 14, 2018

Same

July 11, 2018
August 13, 2018

August 10, 2018
September 10, 2018 (or 31 days
after dispositive motions)

IT IS SO STIPULATED.
Dated May 25, 2018
/s/ Miles N. Clark
Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
KNEPPER & CLARK LLC
Email: [e-mail]
Email: [e-mail]
David H. Krieger, Esq.
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
Email: [e-mail]
Counsel for Plaintiff

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/s/ Alan Ceran
Alan Ceran, Esq. pro hac vice
BURKE, WILLIAMS & SORENSEN, LLP
444 S. Flower St., Ste. 2400
Los Angeles, CA 90071
Email: [e-mail]
Richard J. Reynolds, Esq.
BURKE, WILLIAMS & SORENSEN, LLP
1851 East First Street, Suite 1550
Santa Ana, CA 92705, CA 92705
Email: [e-mail]
Michael R. Brooks, Esq.
KOLESAR & LEATHAM
400 S. Rampart Boulevard, Suite 400
Las Vegas, NV 89145
Email: [e-mail]
Counsel for Defendants

ORDER
IT IS SO ORDERED.

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5-29-2018
Dated: ____ _____

UNITED STATES MAGISTRATE JUDGE

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