United States District Court, D. Nevada
KNEPPER & CLARK LLC MATTHEW I. KNEPPER, ESQ. MILES N.
CLARK, ESQ. SHAINA R. PLAKSIN, ESQ., HAINES & KRIEGER LLC
DAVID H. KRIEGER, ESQ., COUNSEL FOR PLAINTIFF
ALVERSON TAYLOR & SANDERS KURT R. BONDS, ESQ. TREVOR
WAITE, ESQ. COUNSEL FOR DEFENDANT C. SYSTEM, INC.
(PROPOSED) STIPULATION AND ORDER TO EXTEND
to Fed.R.Civ.P. 26(f), and Local Rule 26-1, Plaintiff Seyed
Riazi (“Plaintiff”), Defendant Equifax
Information Services LLC (“Equifax”); and I.C.
System, Inc (“IC System”); (collectively the
“Parties”), by and through their attorneys,
hereby stipulate to extend discovery deadlines and other
deadlines in the February 26, 2019 Scheduling Order as
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.
served discovery requests upon Equifax on February 14, 2019.
Plaintiff also served discovery requests upon IC System on
February 22, 2019. Both Defendants responded to
Plaintiff's discovery requests on March 22, 2019.
Parties anticipate at least one deposition, IC System's
30(b)(6) deponent. This deposition was originally noticed for
April 3, 2019. On April 2, 2019, IC System made Plaintiff
aware of its unavailability for that date. As such, Plaintiff
served an Amended Notice of Deposition as to IC System's
30(b)(6) deponent on April 3, 2019, for the mutually agreed
upon date of May 3, 2019. Plaintiff also intends to subpoena
documents from and depose third party Seton Edgar B.
Davis's 30(b)(6) witness. Plaintiff further intends to
explore this information through expert testimony.
eve of deposition, IC System informed Plaintiff that it was
not available for its deposition. Plaintiff worked with IC
System's counsel to find a new date, which is May 3,
2019. The Parties need to extend the current deadlines the
preserve Plaintiff's rights in place at the original
the Parties are requesting this extension for good cause.
Despite Plaintiff's diligence, given these reasonable
delays, the deposition cannot be held before the current
amend deadline. See Johnson v. Mammoth Recreations,
Inc., 975 F.2d 604, 607 (9th Cir. 1992). The parties
were diligent in seeking an amendment once they reasonably
knew that they could not comply with the scheduling order.
See Eckert Cold Storage, Inc. v. Behl, 943 F.Supp.
1230, 1233 (E.D. Cal. 1996). Specifically, the amend deadline
is currently April 16, 2019, and the parties are filing this
stipulation on April 8, 2019, promptly after the re-noticing
of IC System's deposition. This amended stipulation is
made in good faith, is not interposed for delay, and is not
filed for an improper purpose.
Current Discovery Deadlines.
discovery currently concludes on July 15, 2019, the Parties
plan to complete the above ...