United States District Court, D. Nevada
SHARON BARNUM, JERRY P. CABEBE, ROBERT SUSTRIK, and all similarly situated individuals, Plaintiffs,
EQUIFAX INFORMATION SERVICES, LLC, Defendant.
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
Attorneys for Plaintiffs
Bradley T. Austin, Esq. Nevada Bar No. 13064 Snell &
Wilmer, LLP Zachary A. McEntyre (admitted pro hac vice) Misty
L. Peterson (admitted pro hac vice) King & Spalding LLP
Bryan E. Zubay (admitted pro hac vice) King & Spalding
LLP Attorneys for Defendant EQUIFAX INFORMATION SERVICES, LLC
STIPULATION TO REOPEN EXPERT DEADLINES AND EXTEND
to this Court's Order [ECF Dkt. 81], the parties to this
action have meet and conferred and stipulate that the
Discovery cut-off currently set to close on January 8, 2018,
by this Court's Order, ECF Dkt. 63, should be extended
105 days to April 23, 2018. Good cause exists for this
extension, namely, to resolve Plaintiffs' Emergency
Motion to Extend Close of Discovery and Reopen Expert
Deadlines (the “Emergency Motion”) [ECF Dkt. 75,
76], without requiring Court intervention. The extension
would allow 45 additional days to conduct fact discovery, and
it would reopen the initial and rebuttal expert deadlines.
Statement of Discovery Completed
the second stipulation to continue the class certification
briefing schedule. The stipulation is filed in good faith and
is not intended to cause delay.
1. On February 28, 2017, the Court entered its Initial
Scheduling Order and Protective Order. The Scheduling
Order set discovery to close on August 7, 2017.
2. On May 22, 2017, the Court granted the parties first
stipulation to extend discovery 90 days. This set the
discovery deadline to its previous close on November 8, 2017.
3. On October 20, 2017, the court granted a 60-day extension
of discovery, setting the current close of discovery at
January 8, 2018.
4. On November 15, 2017 Plaintiffs deposed Alicia Fluellen,
Equifax's 30(b)(6) witness.
5. On November 29, 2017, Plaintiffs served Equifax with their
First Set of Requests for Admissions, and First Supplemental
Interrogatories and Requests for Production.
6. On December 7, 2017, nonparty Fidelity Information
Services (“FIS”) produced documents in response
to a subpoena Plaintiffs served on November 17, 2017.
7. On December 13, 2017, Plaintiffs deposed Equifax's
second 30(b)(6) witness, Margaret Leslie.
8. On December 18, Plaintiffs filed the Emergency Motion.
9. On December 19, the Court entered an Order requiring the
parties to conclude their efforts to meet and confer
regarding a stipulation extending discovery, which would
resolve Plaintiffs' Emergency Motion and to ...