Gunter v. United Federal Credit Union et al

Filing 55

ORDER on ECF No. 54 Stipulation : Status Report due 6/14/2016. Class certification motion due by 8/31/2016. Signed by Magistrate Judge William G. Cobb on 6/1/2016. (Copies have been distributed pursuant to the NEF - DRM)

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GREGORY G. GORDON, LTD
Gregory G. Gordon, State Bar No. 5334
[e-mail]
871 Coronado Center Drive, Suite 200
Henderson, Nevada 89052
Ph: [phone] / Fax: [phone]
McCUNEWRIGHT LLP
Richard D. McCune, Pro Hac Vice
[e-mail]
Jae (Eddie) K. Kim, Pro Hac Vice
[e-mail]
2068 Orange Tree Lane, Suite 216
Redlands, California 92374
Ph: [phone] / Fax: [phone]

HOWARD & HOWARD
ATTORNEYS, PLLC
James A. Kohl, Nevada Bar No. 5692
Robert Hernquist, Nevada Bar No. 10616
3800 Howard Hughes Pkwy., Suite 1000
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant United Federal
Credit Union

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HOWARD & HOWARD ATTORNEYS PLLC

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THE KICK LAW FIRM, APC
Taras Kick, Pro Hac Vice
[e-mail]
James Strenio, Pro Hac Vice
201 Wilshire Boulevard
Santa Monica, California 90401
Ph: [phone] / Fax: [phone]

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Attorneys for Plaintiff Tonya Gunter and
the Putative Class

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UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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TONYA GUNTER, individually, and on behalf
of all others similarly situated,

Case No.: 3:15-cv-00483-MMD-WGC
Judge Miranda M. Du

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Plaintiff,

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v.

Stipulation for Extension of Time

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UNITED FEDERAL CREDIT UNION, DOES
1-5 inclusive and ROE CORPORATIONS 6-10
inclusive,
Defendants.

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Stipulation for Extension of Time

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Plaintiff Tonya Gunter (“Gunter”) and defendant United Federal Credit Union (“United”)

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(United and Gunter are collectively referred to as “the Parties”) by and through their respective

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counsel of record, stipulate for the Court to enter an Order amending the Scheduling Order (ECF
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43). As the Parties previously informed the Court, this is a complex consumer class action case

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that requires extensive discovery not only with respect to written discovery, documents

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production and depositions, but also to the defendant credit union’s customer account database,

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which as a result of several mergers, involves multiple complex software platforms, requiring

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substantial expert witness involvement. United has gathered approximately 7,700 documents

HOWARD & HOWARD ATTORNEYS PLLC

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consisting of approximately 450,000 pages that are responsive to the 63 requests for production

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of documents that Plaintiffs propounded. Discovery on class issues prior to the filing of a motion

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for class certification has taken longer than expected, and indeed longer than a typical complex

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credit union overdraft fee case, and therefore, Plaintiff has granted an extension for Defendant to
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respond to her request for production of documents and special interrogatories from March 31 to

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May 27, 2016. Because of this additional complexity and the volume of documents with respect

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to discovery, the parties believe that they need additional time before Plaintiff can prepare a class

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certification motion. The parties submit the following deadlines:

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1. June 16, 2016 at 10:00 a.m. – Telephone status conference with the Court;
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2. August 31, 2016 – Deadline to add parties, conduct class certification discovery, and
to file a class certification motion;
3. October 14, 2016 – Deadline for Defendant to file an opposition to the class
certification motion;

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4. November 18, 2016 – Deadline for Plaintiff to file a reply to the opposition to the class

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certification motion.

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If obstacles arise in meeting the above deadlines, then the parties are to discuss those issue
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with the Court by setting up a status conference call with the Court or raising the issues at the

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above-mentioned telephone status conference.

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Dated: May 26, 2016

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McCUNEWRIGHT, LLP
By:

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/s/ Jae (Eddie) K. Kim (with permission)
Richard D. McCune (Pro Hac Vice))
Jae (Eddie) K. Kim (Pro Hac Vice)

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GREGORY G. GORDON, LTD
Gregory G. Gordon

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HOWARD & HOWARD ATTORNEYS PLLC

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THE KICK LAW FIRM, APC
Taras Kick
James G. Strenio

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Attorneys for Plaintiff Tonya Gunter
and the Putative Class

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Dated: May 26, 2016

HOWARD & HOWARD ATTORNEYS, PLLC
By:

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/s/ James A. Kohl
James A. Kohl
Robert Hernquist

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Attorneys for Defendant United Federal
Credit Union

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IT IS SO ORDERED:

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2016.

It is further ordered that the parties shall file a joint status report on or before June 14,
___________________________________
UNITED STATES MAGISTRATE
JUDGE

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June 1
Dated ________________, 2016.