United States District Court, D. Nevada
& BRASTER Jennifer L. Braster (NBN 9982) Nevada Bar No.
9982 1050 Attorneys for Defendant Experian Information
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
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:
DISCOVERY COMPLETED TO DATE
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
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
8. On July 25, 2017, Experian served its initial disclosures.
9. On July 26, 2017, Plaintiff served his initial