United States District Court, D. Nevada
DOREEN FARMER, and all similarly situated individuals, Plaintiffs,
EXPERIAN INFORMATION SOLUTIONS, INC., Defendant.
Jennifer L Braster, Esq. (NBN 9982) Andrew J Sharples, Esq
(NBN 12866) NAYLOR & BRASTER John Andrew Vogt (NBN 14777)
Edward San Chang (Pro Hac Vice) JONES DAY 3Attorneys for
Experian Information Solutions, Inc.
Matthew I. Knepper, Esq. (NBN 12796) Miles N. Clark, Esq.
(NBN 13848) KNEPPER & CLARK LLC David H. Krieger, Esq.
(NBN 9086) HAINES & KRIEGER, LLC Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND DISCOVERY
to LR 6-1 and LR 26-4, Plaintiff Doreen Farmer
(“Plaintiff) and Experian Information Solutions, Inc.
(“Experian”), by and through their respective
counsel of record, hereby stipulate and request that this
Court extend all case deadlines by sixty (60) days. In
support of this Stipulation and Request, the parties state as
DISCOVERY COMPLETED TO DATE
Plaintiff filed the instant complaint on May 31, 2017.
June 28, 2017, Experian filed its answer.
July 26, 2017, Experian propounded its deposition notice on
Plaintiff, setting Plaintiff's deposition for October 9,
July 31, 2017, the parties submitted their competing plans
August 7, 2017, the Court granted the parties' stipulated
August 9, 2017, Experian provided its initial disclosures.
August 15, 2017, Plaintiff provided her initial disclosures.
August 18, 2017, Plaintiff provided her first supplemental
August 31, 2017, the Court issued its scheduling order,
permitting discovery on both the individual and class
components of Plaintiff's case to proceed simultaneously.
September 21, 2017, Experian propounded its first set of
Requests for Production of Documents on Plaintiff.
September 26, 2017, Plaintiff propounded her first set of
Requests for Admission, Production, and Interrogatories on
Experian, setting Experian's deposition for November 17,
September 26, 2017, Plaintiff propounded her first deposition
notice to Experian.
October 11, 2017, Plaintiff propounded her first amended
deposition notice to Experian, setting Experian's
deposition for November 20, 2017.
October 20, 2017, Plaintiff provided her responses to
Experian's first set of ...