Aycock v. American Express National Bank et al

Filing 63

ORDER granting 62 Stipulation to Extend Deadlines : Response to 52 Motion to Compel due by 12/4/2024. Reply due by 12/18/2024. Signed by Magistrate Judge Elayna J. Youchah on 11/26/2024. (Copies have been distributed pursuant to the NEF - DRM)

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KAEMPFER CROWELL
Robert McCoy, No. 9121
Sihomara L. Graves, No. 13239
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
STEPTOE LLP
Stephen J. Newman (pro hac vice)
Alice Kwak (pro hac vice)
2029 Century Park East, 18th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant American
Express National Bank

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JENNAFER AYCOCK,
Plaintiff,

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vs.

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AMERICAN EXPRESS NATIONAL
BANK; and EXPERIAN
INFORMATION SOLUTIONS, INC.,

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Defendants.

Case No. 2:23-cv-00292-CDS-EJY
AMENDED JOINT STIPULATION
TO EXTEND DEADLINE FOR
AMERICAN EXPRESS TO
RESPOND TO PLAINTIFF’S
MOTION TO COMPEL
DISCOVERY RESPONSES AND
SUPPLEMENTAL DISCLOSURES
(FOURTH REQUEST)

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Plaintiff Jennafer Aycock (“Plaintiff”) and defendant American Express

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National Bank (“American Express”) (collectively, the “Parties”), through their
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respective attorneys of record, hereby submit their Joint Stipulation to extend time

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to respond to Plaintiff’s Motion to Compel Discovery Responses and Supplemental

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Disclosures (ECF No. 52) (the “Motion”), and in support thereof state as follows:

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1.

On October 17, 2024, Plaintiff filed the Motion.

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2.

On October 31, 2024, American Express filed a Stipulation and

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Order extending American Express’ deadline to respond to the Motion by eleven

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(11) days and Plaintiff’s reply by seven (7) days. (ECF No. 53)

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3.

On November 8, 2024, American Express filed a second

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Stipulation and Order further extending American Express’ deadline to respond to

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the Motion by seven (7) days and Plaintiff’s reply by seven (7) days.

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4.

On November 15, 2024, American Express filed a third

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Stipulation and Order further extending American Express’ deadline to respond to

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the Motion by seven (7) days and Plaintiff’s reply by seven (7) days.

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5.

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currently November 25, 2024.

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6.

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American Express’s deadline to respond to the Motion is

Plaintiff’s reply in support of the Motion is currently due

December 9, 2024.
7.

The Parties have agreed to extend the time for American

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Express to respond to the Motion by nine (9) days, up to and including December

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4, 2024, with a reciprocal extension of nine (9) days to the deadline for Plaintiff to

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file a Reply Brief, up to and including December 18, 2024.

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8.

Good cause exists for granting this extension because the

parties require additional time to facilitate resolution of this matter conserve

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judicial resources. The parties have engaged in extensive settlement negotiations

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and the matter appears close to resolution.
9.

This extension is sought in good faith and not for the purpose of

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10.

No party will be prejudiced by the relief sought herein.

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THEREFORE, IT IS HEREBY STIPULATED that the time for

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American Express to respond to the Motion be extended by nine (9) days, up to

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and including December 4, 2024, with a reciprocal extension of nine (9) days to

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the deadline for Plaintiff to file a Reply Brief, up to and including December 18,

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2024.

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KAZEROUNI LAW GROUP, APC

KAEMPFER CROWELL

/s/ Gustavo Ponce
Gustavo Ponce, No. 15084
Mona Amini, No. 15381
6940 South Cimarron Road, Suite 210
Las Vegas, Nevada 89113

/s/ Alice Kwak
Robert McCoy, No. 9121
Sihomara L. Graves, No. 13239
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135

Attorneys for Plaintiff
Jennafer Aycock

STEPTOE LLP
Stephen J. Newman (pro hac vice)
Alice Kwak (pro hac vice)
2029 Century Park East, 18th Floor
Los Angeles, California 90067

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delay.

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Attorneys for Defendant American
Express National Bank
ORDER

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IT IS SO ORDERED.

UNITED STATES DISTRICT JUDGE
DATED: November 26, 2024
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