Mancuso v. USAA Savings Bank et al

Filing 34

ORDER. IT IS ORDERED that 33 the parties' stipulation is GRANTED in part and DENIED in part. See Order for Details. Signed by Magistrate Judge Brenda Weksler on 1/6/2021. (Copies have been distributed pursuant to the NEF - JQC)

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Case 2:20-cv-01656-RFB-BNW Document 34 Filed 01/06/21 Page 1 of 3
The parties stipulated to extending the
deadlines in the DPSO by 3 months. As good
cause, they offer that the holidays have made
Steven A. Alpert, NV Bar #8353
it difficult to marshal enough discovery to give
their experts before the Jan. 29 expert
PRICE LAW GROUP, APC
disclosures deadline. They think depositions
5940 S. Rainbow Blvd., Suite 3014
can start in February.
Las Vegas Nevada, 89118

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T: [phone]
E: [e-mail]

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David A. Chami, AZ Bar #027585
Admitted pro hac vice
PRICE LAW GROUP, APC
8245 N. 85th Way
Scottsdale, AZ 85258
T: [phone]
E: [e-mail]
Attorneys for Plaintiff
Lance Mancuso

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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LANCE MANCUSO,

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Plaintiff,
v.

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I think 3 months seems excessive, so I
recommend granting 2 months, what do you
think?
2 mo is fine

USAA SAVINGS BANK; EXPERIAN
INFORMATION SOLUTIONS, INC.;
EQUIFAX INFORMATION SERVICES,
LLC; and TRANSUNION, LLC.

Case No.: 2:20-cv-01656-RFB-BNW
STIPULATED MOTION FOR
EXTENSION OF SCHEDULING
ORDER DEADLINES
(DOC. 32)
(First Request)

Defendants.

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Plaintiff Lance Mancuso (“Plaintiff”) and Defendants USAA Savings Bank,

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Experian Information Solutions, Inc., Equifax Information Services, LLC and Trans

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Union LLC (collectively, the “Parties”), stipulate and agree that the Court amend its

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Case 2:20-cv-01656-RFB-BNW Document 34 Filed 01/06/21 Page 2 of 3

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Scheduling Order, extending all deadlines by 90 days, and would respectfully show the
Court as follows:

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1. On November 13, 2020, the Court entered the Discovery Plan and Scheduling
Order (Doc. 32).

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2. To date, parties have exchanged written discovery in this matter. Production of

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documents is ongoing, and depositions are upcoming.

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3. In light of the holiday season, and the COVID-19 pandemic, the parties do not

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anticipate completing adequate fact discovery to provide to expert witnesses on or

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before January 29, 2021.

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4. The Parties hereby approach the Court in advance for an amended Scheduling

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Order to seek additional time.

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5. The Parties believe February to be a reasonable time during which the fact and lay

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depositions can take place.

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Considering the foregoing, the Parties respectfully request that this Court extend

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the following deadlines by 90 days:
ORDER

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Deadline for:
Current deadlines:
Amended deadlines:
IT IS ORDERED that the parties' stipulation is GRANTED in part and DENIED in
Disclosure of Experts:
January 29, 2021
April for 2021
part. The Court finds that the parties have not established good cause 29, a 90-day
Rebuttal Instead, the deadlines in the operative DPSO will be extended 2021 days.
February 26, 2021
May 27, by 60
extension. Expert Disclosures:
Discovery Cutoff:
March 30, absolutely cannot28, 2021
June complete
The parties may seek an additional extension if they2021
Dispositive Motion(s):
April 30, 2021
July 29, 2021
discovery within this extended period.
Pretrial Order:
May 31, 2021
August 30, 2021
IT IS SO ORDERED

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DATED: 3:10 pm, January 06, 2021

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Date:

BRENDA WEKSLER
UNITED STATES MAGISTRATE JUDGE

UNITED STATES MAGISTRATE JUDGE

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Case 2:20-cv-01656-RFB-BNW Document 34 Filed 01/06/21 Page 3 of 3

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Respectfully submitted this 29th day of December 2020,
BY: /s/ David A. Chami
David A. Chami, AZ Bar #027585
Admitted pro hac vice
PRICE LAW GROUP, APC
8245 N. 85th Way
Scottsdale, AZ 85258
Email: [e-mail]

By: /s/ Trevor Waite
Trevor Waite, NV Bar #13779
[e-mail]
Kurt Bonds, NV Bar #6228
[e-mail]
ALVERSON TAYLOR & SANDERS
6605 Grand Montecito Pkwy., Ste. 200
Las Vegas, NV 89149

Attorneys for Plaintiff
Lance Mancuso

Attorneys for Defendant
Trans Union LLC

By: /s/ Nora K. Cook
David M. Krueger, OH No. 0085072
Nora K. Cook, OH No. 0086399
200 Public Square, Suite 2300
Cleveland, Ohio 44114-2378

By: /s/ Andrew J. Sharples
Jennifer L. Braster, NV No. 9982
[e-mail]
Andrew J. Sharples, NV No. 12866
[e-mail]
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145

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Robert W. Freeman, NV No. 03062
[e-mail]
Priscilla L. O’briant, NV No. 10171
[e-mail]
Tara U. Teegarden, NV No. 15344
[e-mail]
6385 South Rainbow Blvd., Suite 600
Las Vegas, NV 89118
Attorneys for Defendant
USAA Savings Bank

Katherine A. Neben, NV No. 14590
[e-mail]
JONES DAY
3161 Michelson Drive, Suite 800
Irvine, CA 92612

Attorneys for Defendant
Experian Information Solutions, Inc.

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By: /s/ Jeremy J. Thompson
Jeremy J. Thompson
CLARK HILL, PLLC
3800 Howard Hughes Pkwy, Suite 500
Las Vegas, NV 89169
Email: [e-mail]
Attorneys for Defendant
Equifax Information Services LLC

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