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Farmer v. Experian Information Solutions, Inc.

United States District Court, D. Nevada

July 6, 2018

DOREEN FARMER, and all similarly situated individuals, Plaintiffs,
v.
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 DEADLINES

         Pursuant 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 follows:

         I. DISCOVERY COMPLETED TO DATE

         1. Plaintiff filed the instant complaint on May 31, 2017.

         2. On June 28, 2017, Experian filed its answer.

         3. On July 26, 2017, Experian propounded its deposition notice on Plaintiff, setting Plaintiff's deposition for October 9, 2017.

         4. On July 31, 2017, the parties submitted their competing plans for discovery.

         5. On August 7, 2017, the Court granted the parties' stipulated protective order.

         6. On August 9, 2017, Experian provided its initial disclosures.

         7. On August 15, 2017, Plaintiff provided her initial disclosures.

         8. On August 18, 2017, Plaintiff provided her first supplemental disclosures.

         9. On 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.

         10. On September 21, 2017, Experian propounded its first set of Requests for Production of Documents on Plaintiff.

         11. On September 26, 2017, Plaintiff propounded her first set of Requests for Admission, Production, and Interrogatories on Experian, setting Experian's deposition for November 17, 2017.

         12. On September 26, 2017, Plaintiff propounded her first deposition notice to Experian.

         13. On October 11, 2017, Plaintiff propounded her first amended deposition notice to Experian, setting Experian's deposition for November 20, 2017.

         14. On October 20, 2017, Plaintiff provided her responses to Experian's first set of ...


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