Bangert v. Trans Union, LLC et al

Filing 47

ORDER granting 45 Stipulation to Amend Discovery Plan and Scheduling Order. Discovery due by 7/8/2024. Motions due by 8/23/2024. Proposed Joint Pretrial Order due by 11/4/2024. Signed by Magistrate Judge Brenda Weksler on 5/9/2024. (Copies have been distributed pursuant to the NEF - CT)

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Joel E. Tasca
Nevada Bar No. 14124
Madeleine Coles
Nevada Bar No. 16216
BALLARD SPAHR LLP
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant SoFi Bank, N.A.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Angela Bangert,

[phone] FAX [phone]

Case No. 2:22-cv-01418-RFB-BNW
Plaintiff,

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LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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v.

STIPULATION AND ORDER TO
AMEND DISCOVERY PLAN AND
SCHEDULING ORDER

SoFi Bank N.A., et al.,

(Third Request)

Defendants.

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Defendant SoFi Bank, N.A. (“SoFi”)1 and Plaintiff Angela Bangert (jointly, the

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“Parties”), by and through their respective counsel, hereby stipulate and agree to

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amend the Discovery Plan and Scheduling Order (ECF No. 37) by extending the

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outstanding discovery deadlines for a period of sixty (60) days. This is the third request

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for an extension to the Discovery Plan and Scheduling Order in this matter, and it is

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sought in good faith and not for purposes of delay.

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I.

Discovery Completed

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Plaintiff has served written discovery, including requests for production of

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documents, requests for admission, and interrogatories, to SoFi, and SoFi has

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responded. SoFi has served written discovery, including requests for production of

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documents and interrogatories, to Plaintiff, and Plaintiff has responded. Plaintiff has

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Plaintiff has resolved her claims against Defendants Experian Information Solutions,
Inc. and Equifax Information Services, LLC.

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[phone] FAX [phone]

LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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taken the deposition of SoFi’s 30(b)(6) representative, and SoFi has taken Plaintiff’s

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deposition.

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II.

Discovery That Remains to Be Completed

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Plaintiff has served additional notices of 30(b)(1) depositions of SoFi employees,

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which have not yet occurred. The Parties additionally still need to potentially serve

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additional written discovery, serve third-party subpoenas, conduct third-party

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depositions, and conduct expert discovery.

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III.

Good Cause Exists for the Requested Extension

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The Parties initially stayed discovery pending settlement discussions.

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Following the stay, this Court granted an additional 30-day extension of the discovery

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plan. Although the Parties have cooperated in good faith during that time toward

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meeting their discovery obligations, as the facts in this case have continued to develop,

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and disagreements as to certain facts and discovery have arisen, it has become clear

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that the Parties require additional time to complete discovery, have effective

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conversations, and resolve specific discovery disagreements.

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The additional time will allow the Parties to attempt to resolve the discovery

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issues between themselves, conduct additional fact discovery, and adequately

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determine whether expert discovery will be needed in this matter. Further, no party

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will be prejudiced by the Court granted this Stipulation, as all Parties jointly seek an

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extension of these deadlines. Moreover, the Parties believe that allowing the extension

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will serve the ends of judicial economy.

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As further good cause, Plaintiff contends discovery yielded documents that were

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not timely produced as well as witnesses who were not disclosed until recently –

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Defendant disputes these contentions. In lieu of a Motion to Compel such information,

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the Parties are working together to amicably resolve the discovery dispute without the

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need for Court intervention.

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IV.

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Proposed Discovery Deadlines
The Parties request an order extending the deadlines as set forth below.
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

Discovery Cutoff

07/08/2024

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Deadline to Disclose Expert Disclosures

05/10/2024

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Deadline to Disclose Rebuttal Expert Disclosures

06/07/2024

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Deadline to File Dispositive Motions

08/23/2024

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Pretrial Order: The Parties shall file a joint pretrial order no later than

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11/04/2024 or 30 days after the date set for filing dispositive motions. In the event that

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

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suspended until 30 days after decision on the dispositive motion or further order of the

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Court.

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IT IS SO STIPULATED.

[phone] FAX [phone]

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LAS VEGAS, NEVADA 89135

BALLARD SPAHR LLP

1980 FESTIVAL PLAZA DRIVE, SUITE 900

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DATED this 8th day of May, 2024.
BALLARD SPAHR LLP

LOKER LAW, APC

By: /s/ Madeleine Coles
Joel E. Tasca
Nevada Bar No. 14124
Madeleine Coles
Nevada Bar No. 16216
1980 Festival Plaza Drive, Suite 900
Las Vegas, Nevada 89135

By: /s/ Matthew M. Loker
Matthew M. Loker
Admitted Pro Hac Vice
1303 East Grand Avenue, Suite 101
Arroyo Grande, California 93420

Attorneys for Defendant SoFi Bank,
N.A.

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Michael Kind
Nevada Bar No. 13903
8860 South Maryland Pkwy, Suite 106
Las Vegas, Nevada 89123

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Attorneys for Plaintiff

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KIND LAW

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ORDER

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED: May 9, 2024

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