Roop v. JPMorgan Chase Bank, N.A. et al

Filing 41

ORDER granting 40 Motion to Extend Time re: 33 Order on Discovery Plan and Scheduling Order. Discovery due by 2/14/2022. Motions due by 3/15/2022. Signed by Magistrate Judge Elayna J. Youchah on 11/18/2021. (Copies have been distributed pursuant to the NEF - AF)

Case 2:21-cv-00983-APG-EJY Document 41 Filed 11/18/21 Page 1 of 3

1
2
3
4
5
6
7

Joel E. Tasca
Nevada Bar No. 14124
BALLARD SPAHR LLP
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: 702.471.7070
[e-mail]

Attorneys for Defendant
JPMorgan Chase Bank, National Association

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

[phone] FAX [phone]

CASE NO. 2:21-cv-00983-APG-EJY

Plaintiff,

12
LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

SHIRLEY L. ROOP, an individual;

11
1980 FESTIVAL PLAZA DRIVE, SUITE 900

10

v.

STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES

13

17

JPMORGAN CHASE BANK, N.A., a
national banking association; WELLS
FARGO BANK, N.A., a national banking
association; EQUIFAX INFORMATION
SERVICES, LLC, a foreign limitedliability company; EXPERIAN
INFORMATION SOLUTIONS, INC., a
foreign corporation; INNOVIS DATA
SOLUTIONS, INC., a foreign corporation;

18

Defendants.

14
15
16

(First Request)

19
20

Pursuant to LA IA 6-1, LR 7-1, and LR 26-3, Plaintiff Shirley L. Roop

21

(“Plaintiff”) and Defendant JPMorgan Chase Bank, N.A. (“Chase”) (collectively, “the

22

Parties”), by and through their respective counsel, hereby stipulate and request that

23

the Court extend the discovery deadlines in this matter by 60 days. This is the Parties’

24

first request to extend the discovery deadlines.

25

(a) Statement Specifying the Discovery Completed

26

All Parties have served their initial disclosures pursuant to Fed. R. Civ. P.

27
28

26(a)(1).

Case 2:21-cv-00983-APG-EJY Document 41 Filed 11/18/21 Page 2 of 3

1

Plaintiff served her first set of Interrogatories, Requests for Production, and

2

Requests for Admissions to Chase on August 10, 2021. Chase has not yet served

3

responses.

4

(b) Specific Description of Discovery that Remains to be Completed

5

Chase needs to respond to Plaintiff’s first set of Interrogatories, Requests for

6

Production, and Requests for Admission.

7

Chase needs to serve its first set of discovery requests.

8

The Parties have not taken any depositions or served any deposition requests.

9

All depositions still need to be taken.

[phone] FAX [phone]

(c) The Reasons Why the Deadline Was Not Satisfied or the Remaining

12
LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

The Parties have not started expert discovery.

11
1980 FESTIVAL PLAZA DRIVE, SUITE 900

10

Discovery Was Not Completed Within the Time Limits Set by the Discovery

13

Plan

14

Good cause exists to extend the time to complete the above discovery in order to

15

permit Plaintiff and Chase to respond to and serve written discovery and depose

16

essential witnesses. Over the last three months, the Parties have engaged in good faith

17

settlement discussions, but were unfortunately not able to come to a resolution.

18

(d) Proposed Schedule for Completing All Remaining Discovery

19

The Parties propose a 60-day extension to complete discovery as follows:

20

Event

Current Deadline

Proposed Deadline

21

Expert Disclosures

October 18, 2021

December 17, 2021

22

Rebuttal Expert Disclosures

November 17, 2021

January 17, 2022

23

Close of Discovery

December 15, 2021

February 14, 2022

24

Dispositive Motions

January 14, 2022

March 15, 2022

25
26

[Continued on following page.]

27
28
2

Case 2:21-cv-00983-APG-EJY Document 41 Filed 11/18/21 Page 3 of 3

1
2
3
4
5
6
7
8
9

This is the first request for an extension, and it is made in good faith and not
for purposes of delay.
Dated: November 18, 2021
BALLARD SPAHR LLP

LAW OFFICE OF KEVIN L. HERNANDEZ

By: /s/ Joel E. Tasca
Joel E. Tasca
Nevada Bar No. 14124
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135

By: /s/ Kevin L. Hernandez
Kevin L. Hernandez
Nevada Bar No. 12594
8920 W. Tropicana Avenue, Suite 101
Las Vegas, Nevada 89147

Attorneys for Defendant
JPMorgan Chase, National Association

Attorney for Plaintiff

10

[phone] FAX [phone]

12
LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

11

13
14
15
16
ORDER

17
18

IT IS SO ORDERED:

19
20
21

UNITED STATES MAGISTRATE JUDGE
DATED:

22
23
24
25
26
27
28
3

November 18, 2021