Martinez v. Hope Credit, LLC

Filing 18

ORDER granting 17 Stipulation extending discovery deadlines. Discovery due by 10/28/2024. Motions due by 11/27/2024. Proposed Joint Pretrial Order due by 12/27/2024. Signed by Magistrate Judge Brenda Weksler on 3/27/2024. (Copies have been distributed pursuant to the NEF - MAM)

1 Gustavo Ponce, Esq.

Nevada Bar No. 15084

2 Mona Amini, Esq.

Nevada Bar No. 15381

3 KAZEROUNI LAW GROUP, APC

6787 W. Tropicana Ave., Suite 250

4 Las Vegas, Nevada 89103

Telephone: [phone]

5 Facsimile: [phone]

E-mail: [e-mail]

6 E-mail: [e-mail]
7 Attorneys for Plaintiff,
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MARGARET MARTINEZ
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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11 MARGARET MARTINEZ, individually

and on behalf of all others similarly
12 situated,
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vs.

Plaintiff,

HOPE CREDIT, LLC,
Defendant.

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Case No.: 2:23-cv-01003-BNW
JOINT STIPULATION AND
ORDER EXTENDING
DISCOVERY DEADLINES
(FIRST REQUEST)

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-1STIPULATION

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Plaintiff MARGARET MARTINEZ (“Plaintiff”), and Defendant HOPE

2 CREDIT, LLC (“Defendant”) (the “Parties”) hereby jointly move to extend all
3 deadlines set forth in the Joint Proposed Discovery Plan and Scheduling Order filed
4 with this Court on September 7, 2023, (ECF No. 11) by a period of ninety (90) days.
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The Parties have exchanged initial disclosures and believe that this matter will

6 need more time to flush out the discovery issues and facts. The Parties anticipate
7 review of additional documents and recordings as well as depositions from multiple
8 third-party witnesses. Due to the nature of the facts here, the Parties in good faith
9 believe more time is necessary to conduct efficient discovery and for the Parties to
10 have effective conversations.
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1.

On June 29, 2023, Plaintiff filed her Complaint (ECF No. 1), against

12 Defendant.
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2.

Defendant filed its Answer to Plaintiff’s Complaint on July 26, 2023

14 (ECF No. 6).
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3.

The Parties have completed the following discovery to date:

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• The Parties have exchanged initial disclosures.

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• Plaintiff served Defendant with a request for production of documents,

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request for admissions, and interrogatories on February 9, 2024.

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• Defendant served its responses to Plaintiff’s request for admission on

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February 24, 2024.

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• Defendant served its responses to Plaintiff’s request for production of

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documents and interrogatories on March 6, 2024.
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The parties still need to conduct depositions, potentially additional

24 written discovery, serve subpoenas, conduct third-party depositions, and conduct
25 expert discovery.
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The additional time will allow the Parties to conduct extensive and

27 additional fact discovery, including taking depositions, potentially additional written
28 discovery, acquiring all documents from third-parties, resolving pending discovery
-2STIPULATION

1 issues, and additional time to adequately determine whether expert discovery will be
2 needed in this matter.
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6.

No party will be prejudiced by this Court granting this Stipulation as all

4 Parties jointly seek an extension of these deadlines. Moreover, the Parties believe
5 that allowing the extension will serve the ends of judicial economy.

7.

Moreover, the requested extensions are not sought for the purposes of

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This is the Parties’ first request to extend these deadlines.

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9.

Accordingly, the parties request adoption of the following deadlines:

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7 delay.

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a. Discovery Plan:

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Discovery Cut-off

10/28/2024

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Deadline to Disclose Expert Disclosures

07/01/2024

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Deadline to Disclose Rebuttal Expert Disclosures 07/31/2024

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Deadline for Class Certification

07/31/2024

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Deadline to File Dispositive Motions

11/27/2024

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b. Pre-Trial Order: The parties shall file a joint pretrial order no later

17 than 12/27/2024 or thirty (30) days after the date set for filing dispositive motions. In
18 the event that Parties file dispositive motions, the date for filing the joint pretrial
19 order shall be suspended until thirty (30) days after decision on the dispositive motion
20 or further order of the Court.
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-3STIPULATION

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WHEREFORE, Plaintiff and Defendant respectfully request this Honorable

2 Court (1) extend discovery in the present matter as set forth above; and (2) reissue a
3 new Scheduling Order to reflect the requested extension.
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5 Dated this 26th day of March 2024.
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KAZEROUNI LAW GROUP, APC

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By: /s/ Gustavo Ponce
Gustavo Ponce, Esq.
10 Mona Amini, Esq.
11 6787 W. Tropicana Ave., Suite 250
Las Vegas, Nevada 89103
12 Attorneys for Plaintiff
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COREY READE DOWS &
SHAFER
By: /s/ Christopher Reade
R. Christopher Reade, Esq.
Rowland Graff, Esq.
1333 North Buffalo Drive, Suite 210
Las Vegas, Nevada 89128
Attorneys for Defendant
Consortium Corporation d/b/a Hope
Credit LLC

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ORDER
IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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-4STIPULATION

3/27/2024

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CERTIFICATION OF SERVICE
I HEREBY CERTIFY pursuant to Rule 5 of the Federal Rules of Civil

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Procedure that on March 26, 2024, the foregoing JOINT STIPULATION AND

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ORDER EXTENDING DISCOVERY DEADLINES was served via CM/ECF to all

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parties appearing in this case.

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KAZEROUNI LAW GROUP, APC

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By: /s/ Gustavo Ponce
Gustavo Ponce, Esq.
Mona Amini, Esq.
6787 W. Tropicana Ave., Suite 250
Las Vegas, NV 89103

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-2STIPULATION