Bliss v. CoreCivic, Inc.

Filing 207

ORDER Granting 206 Stipulation for Extension of Joint Status Report. Joint Status Report due by 8/17/2022. Signed by Magistrate Judge Elayna J. Youchah on 8/2/2022. (Copies have been distributed pursuant to the NEF - KF)

Case 2:18-cv-01280-JAD-EJY Document 207 Filed 08/02/22 Page 1 of 4

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Daniel P. Struck
Arizona Bar No. 012377
(admitted pro hac vice)
Jacob B. Lee
Nevada Bar No. 012428
Ashlee B. Hesman
Nevada Bar No. 012740
STRUCK LOVE BOJANOWSKI & ACEDO, PLC
3100 West Ray Road, Suite 300
Chandler, Arizona 85226
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
Gina G. Winspear
Nevada Bar No. 005552
DENNETT WINSPEAR, LLP
3301 North Buffalo Drive, Suite 195
Las Vegas, Nevada 89129
Telephone: [phone]
[e-mail]
Attorneys for Defendant CoreCivic, Inc.
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
Kathleen Bliss, on behalf of herself, the
Proposed Nationwide Rule 23 Class, and the
Proposed Nevada Subclass,
Plaintiff,

Case No. 2:18-cv-01280-JAD-GWF
STIPULATION FOR EXTENSION OF
JOINT STATUS REPORT

v.
CoreCivic, Inc.,
Defendant.

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This is the first stipulation for extension of time to file this joint status report. Kathleen Bliss

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(“Plaintiff”) and CoreCivic, Inc. (“CoreCivic”) (collectively, the “parties”), through their

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respective counsel, stipulate and agree to the following:

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WHEREAS, on June 2, 2022, the Court ordered, among other things, Defendant to

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supplement its document production and written discovery responses, ordered the parties to meet

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Case 2:18-cv-01280-JAD-EJY Document 207 Filed 08/02/22 Page 2 of 4

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and confer, and ordered the parties to file a status report noting, among other things, whether they

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had scheduled a subsequent meet-and-confer. (ECF No. 200.)

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WHEREAS, on July 8, 2022, the parties filed the ordered status report, noting that they had

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scheduled a subsequent meet-and-confer for July 21 and stating that Defendant would supplement

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its document production and written responses again on July 28, 2022. (ECF No. 205.)

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WHEREAS, the July 8 status report stated the parties’ self-imposed deadline of August 1,
2022 to file a subsequent status report. (ECF No. 205.)

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WHEREAS, the parties met and conferred on July 21, and Defendant supplemented its
document production and written responses on July 28.
WHEREAS, the parties dispute whether Defendant’s July 28 production and written
responses are consistent with their earlier agreements and dispute whether and to what extent the
production and written responses are deficient or compliant.
WHEREAS, the dispute over the July 28 production and written responses covers many
topics.
WHEREAS, a subpoena response date related to underlying disputes is set for August 12,
Defendant’s counsel will be in trial August 10-12 and has significant deadlines in other class action
matters between now and August 12, and the parties believe that they, and the Court, would likely
be better served by the parties meeting and conferring about their disputes, narrowing the
outstanding disputes for the Court’s review, and submitting a status report that reflects a more
thorough review of the July 28 production and written responses.
WHEREFORE, the parties STIPULATE AND AGREE to meet and confer with each other
on August 4, 2022 at 2 p.m. Pacific and extend the time to file their second status report from
August 1 to August 17, 2022.

DATED this 1st day of August, 2022.
NICHOLS KASTER, PLLP

STRUCK LOVE BOJANOWSKI & ACEDO,
PLC
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Case 2:18-cv-01280-JAD-EJY Document 207 Filed 08/02/22 Page 3 of 4

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s/Anna P. Prakash__________________
Matthew H. Morgan* MN Bar No. 304657
Anna P. Prakash* MN Bar No. 0351362
Charles A. Delbridge* MN Bar No. 0386639
Rebekah L. Bailey* MN Bar No. 0389599
Charles J. O’Meara* MN Bar No. 0402777
NICHOLS KASTER, PLLP
4700 IDS Center
80 South 8th Street
Minneapolis, MN 55402
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
NICHOLS KASTER, LLP
Matthew C. Helland* CA Bar No. 250451
235 Montgomery St., Suite 810
San Francisco, CA 94104
Telephone: [phone]
[e-mail]

s/Anne M. Orcutt
Daniel P. Struck
Rachel Love
Jacob B. Lee
Ashlee B. Hesman
Anne M. Orcutt
Eden G. Cohen
3100 West Ray Road, Suite 300
Chandler, AZ 85226
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Gina G. Winspear
DENNETT WINSPEAR
3301 North Buffalo Dr., Suite 195
Las Vegas, NV 89129
[e-mail]
Attorneys for Defendant CoreCivic, Inc

Michael Hodgson* MO Bar No. 63677
THE HODGSON LAW FIRM, LLC
3609 SW Pryor Road
Lee’s Summit, MO 64082
Tel: [phone]
[e-mail]
Lance D. Sandage* MO Bar No. 46022
SANDAGE LAW LLC
1600 Genessee Street, Suite 655
Kansas City, MO 64102
Tel: [phone]
[e-mail]
Joseph K. Eischens* MO Bar No. 44706
LAW OFFICE OF JOSEPH K. EISCHENS
8013 Park Ridge Dr.
Parkville, MO 64152
Tel: [phone]
[e-mail]
Paul S. Padda
NV Bar No. 10417

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Case 2:18-cv-01280-JAD-EJY Document 207 Filed 08/02/22 Page 4 of 4

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PAUL PADDA LAW, PLLC
4560 South Decatur Blvd., Suite 300
Las Vegas, NV 89103
Tel: [phone]
[e-mail]
*Admitted pro hac vice
Attorneys for Plaintiff and the Proposed
Classes
IT IS SO ORDERED:

UNITED STATES MAGISTRATE JUDGE
DATED:

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August 2, 2022