Flores v. Equifax Information Services, LLC

Filing 14

SCHEDULING ORDER granting 13 Discovery Plan and Scheduling Order - Discovery due by 2/14/2022. Motions due by 3/15/2022. Proposed Joint Pretrial Order due by 4/15/2022. Signed by Magistrate Judge Brenda Weksler on 9/7/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:21-cv-00974-JAD-BNW Document 13 Filed 09/03/21 Page 1 of 5
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09/07/21

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David H. Krieger, Esq.
Nevada Bar No. 9086
Shawn W. Miller, Esq.
Nevada Bar No. 7825
KRIEGER LAW GROUP, LLC
2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052
Phone: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff,
Gloria Flores
UNITED STATES DISTRICT COURT

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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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DISTRICT OF NEVADA

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GLORIA FLORES,

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Case No.: 2:21-cv-00974-JAD-BNW

Plaintiff(s),
vs.
EQUIFAX INFORMATION SERVICES,
LLC,

DISCOVERY PLAN AND
PROPOSED SCHEDULING
ORDER

Defendant(s).
SUBMITTED IN COMPLIANCE WITH LR 26-1(b)
Gloria Flores (“Plaintiff”) and Equifax Information Services, LLC (“Equifax”),
collectively the “Parties”, by and through their counsel of record, hereby submit their
stipulated Discovery Plan and Scheduling Order pursuant to Federal Rule of Civil
Procedure 16 and 26, as well as LR 16-1 and 26-1. It is hereby requested that the Court
enter the following discovery plan and scheduling order:

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Case 2:21-cv-00974-JAD-BNW Document 13 Filed 09/03/21 Page 2 of 5
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1. Discovery Plan:
Discovery Cut-Off:

February 14, 2022 (180 days from the
date Defendant filed its Answer, August
16, 2021).

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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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Deadline to Amend Pleadings:

November 15, 2021 (90 days prior to the
close of discovery).

Deadline to Disclose Initial
Expert Disclosures:

December 15, 2021 (60 days prior to the
close of discovery).

Deadline to Disclose Rebuttal
Expert Disclosures:

January 14, 2022 (30 days after
the Initial Disclosure of Experts).

Deadline to File Dispositive
Motions:

March 15, 2022 (30 days after the close
of discovery).

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2. Pre-Trial Order: The Parties shall file a joint pretrial order no later than April
15, 2022 or thirty (30) days after the date set for filing dispositive motions. In the event

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that the Parties file dispositive motions, the date for filing the joint pretrial order shall be

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suspended until thirty (30) days after decision on the dispositive motions or further order

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of the Court. The disclosure required by Federal Rule of Civil Procedure 26(a)(3) and
objections thereto shall be made in the pre-trial order.
3. Initial Disclosures: The Parties shall make initial disclosures on or before

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September 16, 2021. Any Party seeking damages shall comply with Federal Rules of

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Civil Procedure 26(a)(1)(A)(iii).

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4. Extension of Discovery Deadline: Requests to extend the discovery shall
comply fully with LR IA 6-1 and 26-3.

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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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5. Electronically Stored Information (“ESI”): The Parties stipulate and agree
that all discoverable documents will be produced in electronic format, text searchable
when reasonably practicable, and provided in electronic formats that are widely available
and accessible (e.g., CD-ROM, DVD, USB storage device, PDF, MP3, WAV, MIDI).
The Parties further agreed that the “parent-child relationships” between documents will
be preserved when documents are produced (e.g., e-mails and their attachments will be
produced together with consecutive bates numbers) as reasonably practicable. While the
Parties agree at this time that it is not necessary to produce the metadata for electronic
documents, the Parties reserve their respective rights to request such information should

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any Party deem it necessary. This agreement only determines the format in which the

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Parties produce documents; it does not affect any other right of any Party.

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6.

LR 26-1(b)(7) CERTIFICATIONS:

The Parties certify that they

considered consenting to trial by a magistrate judge and use of the Short Trial Program.
The Parties further certify that they met and conferred about the possibility of using

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alternative dispute resolution processes including, mediation, arbitration, and early neutral

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evaluation.

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7. Electronic Service and Electronic Evidence (LR 26-1(b)(9)): The Parties
agree to accept electronic service of discovery requests, discovery responses and other
papers pursuant to Federal Rule of Civil Procedure 5(b)(2)(E). The Parties discussed
whether they intend to present evidence in electronic format to jurors for the purpose of

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jury deliberations and agreed that should discovery be provided in an electronic format at
trial, it will be compatible with the court’s electronic jury evidence display system
pursuant to LR 26-1(b)(9).

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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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8. Protective Orders: Any Party may seek to enter into a stipulated protective
order pursuant to Federal Rule of Civil Procedure 26(c) prior to producing any confidential
documents in its possession. Such Party shall circulate a proposed protective order with
its responses to the applicable discovery requests and, to the extent such Party is
withholding documents, such Party shall produce those withheld documents subject to an
entered protective order within two weeks from the date the court enters the protective

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order.

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Case 2:21-cv-00974-JAD-BNW Document 13 Filed 09/03/21 Page 5 of 5
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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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9. Responses to Discovery served prior to the Rule 26(f) conference: Unless
agreed otherwise by the Parties, responses to discovery served prior to the Federal Rule
of Civil Procedure 26(f) conference shall be due 33 days after the conference.
Dated September 3, 2021.
/s/ Shawn W. Miller
.
David H. Krieger, Esq.
Shawn W. Miller, Esq.
KRIEGER LAW GROUP, LLC
2850 W. Horizon Ridge Parkway
Suite 200
Henderson, Nevada 89052
Attorneys for Plaintiff
Gloria Flores

/s/ Jeremy J. Thompson
.
Jeremy J. Thompson, Esq.
CLARK HILL PLLC
3800 Howard Hughes Drive
Suite 500
Las Vegas, Nevada 89169
Attorneys for Defendant
Equifax Information Services, LLC

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SCHEDULING ORDER

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The above-set stipulated Discovery Plan of the parties shall be the Scheduling Order
for this action pursuant to Federal Rule of Civil Procedure 16(b) and Local Rule 16-1.
IT IS SO ORDERED.
______________________________________
United States Magistrate Judge
September 7, 2021.
Dated: _________________________________

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