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Zimmerman v. Acctcorp of Southern Nevada, Inc.

United States District Court, D. Nevada

March 23, 2018

DEBORAH ZIMMERMAN, Plaintiff,
v.
ACCTCORP OF SOUTHERN NEVADA, INC.; BARCLAYS BANK DELAWARE; EQUIFAX INFORMATION SERVICES, LLC; EXPERIAN INFORMATION SOLUTIONS, INC.; TRANS UNION, LLC; and VONS CREDIT UNION, Defendants.

          Matthew I. Knepper, Esq., Miles N. Clark, Esq., KNEPPER & CLARK LLC, David H. Krieger, Esq., HAINES & KRIEGER, LLC, Counsel for Plaintiff

          Jennifer L. Braster, Esq., Andrew J. Sharples, Esq., NAYLOR & BRASTER, Counsel for Experian Information Solutions, Inc.

          Jason Revzin, Esq., LEWIS BRISBOIS BISGAARD & SMITH, Counsel for Defendant Trans Union LLC

          [PROPOSED] STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER

         Plaintiff DEBORAH ZIMMERMAN (“Plaintiff”) and Defendants TRANS UNION LLC (“Trans Union”) and EXPERIAN INFORMATION SOLUTIONS, INC., (“Experian”) (collectively, the “Parties”)[1], by and through their counsel of record, hereby submit their stipulated 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

7/30/2018 (180 days from the date Experian, filed its Answer, 1/29/2018)

Deadline to Amend Pleadings

5/1/2018 (90 days prior to the close of discovery)

Deadline to Disclose Initial Expert Disclosures

5/31/2018 (60 days prior to the close of discovery)

Deadline to Disclose Rebuttal Expert Disclosures

7/2/2018 (30 days after the Initial Disclosure of Experts)

Deadline to File Dispositive Motions

8/29/2018 (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 5/31/2018 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 9/28/2018 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 served their initial disclosures on or before 3/14/2018. Any party seeking damages shall comply with 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 6-1, be supported by a showing of good cause for the extension.

         The motion or stipulation shall include:

a. A statement specifying the discovery completed by the parties as of the date of the motion or stipulation;
b. A specific description of the discovery which remains to be completed;
c. The reasons why such remaining discovery was not completed within the time limit of the existing ...

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