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., MILES N. CLARK, ESQ., KNEPPER &
CLARK, LLC DAVID H. KRIEGER, ESQ., HAINES & KRIEGER, LLC
ATTORNEYS FOR PLAINTIFFS
BRADLEY T. AUSTIN, ESQ. SNELL & WILMER, LLP, ZACHARY A.
MCENTYRE MISTY L. PETERSON KING & SPALDING LLP, BRYAN E.
ZUBAY KING & SPALDING LLP ATTORNEYS FOR DEFENDANT EQUIFAX
INFORMATION SERVICES, LLC
STIPULATION TO EXTEND DISCOVERY DEADLINES
to Fed.R.Civ.P. 26(f), and Local Rule 26-1, Plaintiffs SHARON
BARNUM and ROBERT SUSTRIK (“Plaintiffs”),
Defendant EQUIFAX INFORMATION SERVICES, LLC
(“Equifax”); (together with Plaintiff, the
“Parties”), by and through their attorneys,
hereby stipulate to stay discovery and to extend discovery
deadlines and other deadlines in the December 21, 2017
Scheduling Order as follows:
parties do not propose any changes to the form of disclosures
required pursuant to Federal Rule 26(a). The Parties already
served their initial disclosures.
the third stipulation to continue the class certification
briefing schedule. The stipulation is filed in good faith and
is not intended to cause delay.
February 28, 2017, the Court entered its Initial Scheduling
Order and Protective Order. The Scheduling Order set
discovery to close on August 7, 2017.
May 22, 2017, the Court granted the parties first stipulation
to extend discovery 90 days.
Between May 30, 2017 and October 20, 2017, the Parties
engaged in extensive discovery, including exchanging written
discovery responses, producing documents, and taking
depositions of Plaintiffs.
October 20, 2017, the Court granted a 60-day extension of
discovery, setting the current close of discovery at January
Between October 20, 2017 and the present, Plaintiffs deposed
two Rule 30(b)(6) witnesses of Equifax and served additional
written discovery, to which Equifax timely responded. The
Parties also engaged in extensive discussions regarding
outstanding discovery issues.
December 21, 2017, the Court entered a Scheduling Order
setting discovery to close on April 23, 2018.
January 19, 2018, in accordance with the Court's
instructions, the Parties filed a Joint Statement, which ...