Bryant v Madison Management Services, LLC, et al

Filing 29

ORDER granting 28 Stipulation to Extend Discovery Deadlines. Discovery due by 4/5/2021. Motions due by 5/4/2021. Proposed Joint Pretrial Order due by 6/8/2021. Signed by Magistrate Judge Elayna J. Youchah on 10/27/2020. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00594-JAD-EJY Document 29 Filed 10/27/20 Page 1 of 4

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George Haines, Esq.
Nevada Bar No. 9411
FREEDOM LAW FIRM
8985 S. Eastern Avenue, Ste. 350
Beltway Corporate Center
Las Vegas, NV 89123
Telephone:[phone]
[e-mail]
Counsel for Plaintiff Lisa A. Bryant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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:
:
:
:
Plaintiff,
:
:
v.
:
MADISON MANAGEMENT SERVICES, :
LLC, and WALDMAN & PORRAS, PLLC, :
:
:
Defendants.
:
:
LISA A. BRYANT,

Case No.: 2:20-cv-00594-JAD-EJY

[PROPOSED] STIPULATION AND
ORDER TO EXTEND DISCOVERY
[FIRST REQUEST]

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Pursuant to Fed. R. Civ. P. 26(f), and Local Rule 26-1, Plaintiffs Jeffrey K. Engler and

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Katherine M. Sennes-Engler (“Plaintiffs”) and CMG Mortgage Inc. d/b/a CMG Financial

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(“CMG”) (collectively the “Parties”), by and through their attorneys, hereby stipulate to extend

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discovery deadlines and other deadlines in the March 11, 2020 Scheduling Order (ECF No. 24)

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as follows:

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1.

Completed Discovery.

The parties have exchanged initial disclosures. Plaintiff has served written discovery.
2.

Remaining Discovery.

Written discovery responses from Defendants and the parties’ depositions.

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Case 2:20-cv-00594-JAD-EJY Document 29 Filed 10/27/20 Page 2 of 4

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3. Good Cause.

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On October 5, 2020, Defendants filed a Motion for Extension of Time to Responds to

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Discovery Requests (“Motion for Extension”) because Defendants are working remotely and on a

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reduced staff due to the Covid 19 pandemic. See ECF No. 25. On October 21, 2020, the Court

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granted Defendants’ Motion for Extension and Defendants’ discovery responses are now due on

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November 4, 2020. See ECF No.26.

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Thus, the parties are seeking a 90-day extension to ensure that the pending discovery can

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be completed without requesting additional time. This stipulation is made in good faith, is not

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interposed for delay, and is not filed for an improper purpose. Furthermore, a trial date has not

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been set at this time.

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5.

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 Discovery Cutoff: January 5, 2021

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 Deadline to Amend Pleadings: October 7, 2020

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 Deadline to Disclose Initial Expert Disclosures: November 6, 2020

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 Deadline to Disclose Rebuttal Expert Disclosures: December 7, 2020

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 Dispositive Motion Deadline: February 4, 2021

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Current Discovery Deadlines.

 Joint Proposed Pretrial Order: March 8, 2021
6.

Proposed Discovery Deadlines.
 Discovery Cutoff: April 5, 2021
 Deadline to Amend Pleadings: January 7, 2021
 Deadline to Disclose Initial Expert Disclosures: February 6, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: March 7, 2021
 Dispositive Motion Deadline: May 4, 2021
 Joint Proposed Pretrial Order: June 8, 2021

WHEREAS, no prejudice will occur to this Court or the Parties if granted, good cause
supports this request to extend discovery;
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Case 2:20-cv-00594-JAD-EJY Document 29 Filed 10/27/20 Page 3 of 4

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NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS
HEREBY STIPULATED AND AGREED, by and between the Parties as follows:
The August 19, 2020 Scheduling Order shall be amended as follows:
 Discovery Cutoff: April 5, 2021
 Deadline to Amend Pleadings: January 7, 2021
 Deadline to Disclose Initial Expert Disclosures: February 6, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: March 7, 2021
 Dispositive Motion Deadline: May 4, 2021
 Joint Proposed Pretrial Order: June 8, 2021
IT IS SO STIPULATED.
DATED: October 25, 2020

DATED: October 25, 2020

FREEDOM LAW FIRM, LLC

WALDMAN & PORRAS, PLLC

By: /s/ George Haines
GEORGE HAINES, ESQ.
Nevada Bar No.: 9411
8985 S. Eastern Ave., Suite 350
Las Vegas, NV 89123
Attorney for Plaintiff
LISA BRYANT

By: /s/ Nicholas M. Porras
NICOLAS M. PORRAS, ESQ.
Nevada Bar No.: 12849
201 West Liberty Street, Suite 207
Reno, NV 89501
Attorney for Defendants
MADISON MANAGEMENT SERVICES,
LLC, AND PORRAS, PLLC

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Case 2:20-cv-00594-JAD-EJY Document 29 Filed 10/27/20 Page 4 of 4

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ORDER GRANTING
STIPULATION TO EXTEND DISCOVERY
In consideration of the parties’ stipulation and good cause showing, IT IS ORDERED
THAT the August 19, 2020 Scheduling Order shall be amended as follows:
 Discovery Cutoff: April 5, 2021
 Deadline to Amend Pleadings: January 7, 2021
 Deadline to Disclose Initial Expert Disclosures: February 6, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: March 7, 2021
 Dispositive Motion Deadline: May 4, 2021
 Joint Proposed Pretrial Order: June 8, 2021
IT IS SO ORDERED.
________________________________________
UNITED STATES MAGISTRATE JUDGE

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Dated: October 27, 2020

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