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Leoni v. Experian Information Solutions, Inc.

United States District Court, D. Nevada

July 28, 2017

DAVID LEONI, Plaintiff,
v.
EXPERIAN INFORMATION SOLUTIONS, INC. and MILITARY STAR, Defendants.

          NAYLOR & BRASTER Jennifer L. Braster (NBN 9982) Nevada Bar No. 9982 1050 Attorneys for Defendant Experian Information Solutions, Inc.

          KNEPPER & CLARK, LLC Matthew I. Knepper (NBN 12796) Miles N. Clark (NBN 13848) 10040 David H. Krieger Nevada Bar No. 9086 HAINES & KRIEGER, LLC 8985 Attorneys for Plain

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES [FIRST REQUEST]

         Pursuant to LR 6-1 and LR 26-4, Plaintiff and Experian Information Solutions, Inc., by and through their respective counsel of record, hereby stipulate and request that this Court extend the motion to amend deadline by fifty (50) days. At this time, the parties are not seeking an extension of any other discovery deadlines but reserve the right to request in the future. In support of this Stipulation and Request, the parties state as follows:

         I. DISCOVERY COMPLETED TO DATE

         Presently, the active parties to this case are Plaintiff and Experian Information Solutions, Inc. (“Experian”), and as such, the recitation of discovery shall be with respect to Plaintiff and Experian.

1. Plaintiff filed the instant complaint on May 18, 2017.
2. On June 12, 2017, Experian filed its answer.
3. On June 23, 2017, the parties held the Rule 26 Conference.
4. On June 23, 2017, Plaintiff served Experian with requests for admission, requests for production of documents, and interrogatories. Experian responded on July 24, 2017.
5. On June 23, 2017, Plaintiff served Experian with a notice of deposition, setting the deposition of Experian's 30(b)(6) designee for August 1, 2017. Experian's witness is not available on August 1, 2017, but is available on September 15, 2017. Plaintiffs counsel has agreed to this date provided the parties stipulate to the extension of the motion to amend deadline until 50 days after the renoticed deposition date and Plaintiffs deposition occurs after Experian's deposition.
6. On July 5, 2017, the parties submitted a proposed Discovery Plan and Scheduling Order.
7. On July 6, 2017, the Stipulated Protective Order was entered.
8. On July 25, 2017, Experian served its initial disclosures.
9. On July 26, 2017, Plaintiff served his initial ...

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