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Ishikawa v. USAA Federal Savings Bank, National Association

United States District Court, D. Nevada

May 18, 2017

SUZANNE D. ISHIKAWA, Plaintiff,
v.
USAA FEDERAL SAVINGS BANK, NATIONAL ASSOCIATION; EXPERIAN INFORMATION SOLUTIONS, INC., Defendants.

          Matthew I. Knepper, Esq. Nevada Bar No. 12796 Miles N. Clark, Esq. Nevada Bar No. 13848 KNEPPER & CLARK LLC David H. Krieger, Esq. Nevada Bar No. 9086 HAINES & KRIEGER, LLC Counsel for Plaintiff.

          Jennifer L. Braster, Esq. Nevada Bar No. 9982 NAYLOR & BRASTER Counsel for Experian Information Solutions, Inc.

          [PROPOSED] STIPULATED AMENDED DISCOVERY PLAN AND SCHEDULING ORDER

         SUBMITTED IN COMPLIANCE WITH LR 26-1(b)

         In accordance with this Court's Scheduling Order [ECF Dkt. 39], on April 28, 2017, the parties met and conferred pursuant Rule 26(f). IT IS HEREBY STIPULATED by and between Plaintiff SUZANNE D. ISHIKAWA (“Plaintiff”), and Defendant EXPERIAN INFORMATION SOLUTIONS, INC., (“Experian”), by and through their counsel of record, hereby submit their stipulated Amended Discovery Plan and Scheduling Order pursuant to Federal Rule of Civil Procedure 16 and 26, as well as LR II 16-1 and 26-1. It is hereby requested that the Court enter the following discovery plan and scheduling order:

         1. Discovery Plan:

Discovery Cut-Off

8/21/2017 (180 days from the date Experian Information Solutions, Inc., filed its Answer, 2/21/2017)

Deadline to Amend Pleadings

5/22/2017 (90 days prior to the close of discovery)

Deadline to Disclose Initial Expert Disclosures

6/21/2017 (60 days prior to the close of discovery)

Deadline to Disclose Rebuttal Expert Disclosures

7/21/2017 (30 days after the Initial Disclosure of Experts)

Deadline to File Dispositive Motions

9/19/2017 (30 days after the close of discovery)

         2. Interim Status Report:

         The parties shall file the interim status report required by LR 26-3 no later than 6/21/2017 or sixty-one (60) days prior to the close of discovery.

         3. Pre-Trial Order:

         The parties shall file a joint pretrial order no later than 10/19/2017 or thirty (30) days after the date set for filing dispositive motions. In the event that parties file dispositive motions, the date for filing the joint pretrial order shall be suspended until thirty (30) days after decision on the dispositive motions or further order of the Court. The disclosure required by Federal Rule of Civil Procedure 26(a)(3) and objections thereto shall be made in the pre-trial order.

         4. Initial Disclosures:

         The parties' initial disclosures shall be served on or before 5/12/2017. Any party seeking damages shall comply Federal Rules of Civil Procedure 26(a)(1)(A)(iii).

         5. Extension of Discovery Deadline:

         Requests to extend the discovery shall comply fully with LR 26-4. Applications to extend any date set by the discovery plan, scheduling order, or other order must, in addition to satisfying the requirements of LR IA ...


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