United States District Court, D. Nevada
CRAIGK. PERRY & ASSOCIATES Craig K. Perry, Esq. Attorneys
for Plaintiff Millie Phung Shiu
HILL PLLC Nicholas M. Wieczorek, Esq. Jeremy J. Thompson,
Esq. Attorneys for Defendant Equifax Information Services LLC
STIPULATION AND ORDER TO EXTEND TIME (FIRST
to LR 26-4, plaintiff Millie Phung Shu and defendant Equifax
Information Services, LLC, by and through their respective
counsel of record, hereby stipulate to modify the Court's
Scheduling Order, dated January 29, 2019 (ECF No. 19), to
extend the dispositive motion deadline
Parties note that no Party has failed to meet any discovery
deadline and that the dispositive motion deadline is not
within 21 days. The purpose of this request is to extend the
dispositive motion deadline so that the Parties can continue
to focus their time and resources on the disposition of this
matter without further litigation.
Parties have served initial disclosures.
Parties have exchanged written discovery.
Discovery That Remains to Be Completed
recent discussions regarding settlement, Plaintiff requested
an extension to submit her discovery responses to August 1,
Discovery Has Not Been Completed
Parties have not failed to timely complete any discovery. The
discovery cutoff occurred on July 19, 2019. However, due to
recent settlement discussions, the Parties agreed to extend
Plaintiff's deadline to serve her written discovery
responses to August 1, 2019. Because of that extension, the
Parties seek to extend the current dispositive motion
deadline of August 16, 2019 so that Equifax has sufficient to
time to review Plaintiff's discovery responses and
evaluate whether a dispositive motion is necessary
the Parties seek the extension requested herein in order to
facilitate disposition of the action without further
litigation. The Parties have been diligently working towards
Parties agree that no Party will suffer any prejudice as a
result of the relief requested herein. To the contrary, the
proposed extension will facilitate a more efficient
disposition of this action and preserve judicial resources.
foregoing constitutes good cause to amend the existing
Scheduling Order ...