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Shiu v. Equifax Information Services LLC

United States District Court, D. Nevada

July 24, 2019

MILLIE PHUNG SHIU, Plaintiff,
v.
EQUIFAX INFORMATION SERVICES LLC, Defendant.

          CRAIGK. PERRY & ASSOCIATES Craig K. Perry, Esq. Attorneys for Plaintiff Millie Phung Shiu

          CLARK HILL PLLC Nicholas M. Wieczorek, Esq. Jeremy J. Thompson, Esq. Attorneys for Defendant Equifax Information Services LLC

          STIPULATION AND ORDER TO EXTEND TIME (FIRST REQUEST)

         Pursuant 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 only.

         The 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.

         A. Discovery Completed

         The Parties have served initial disclosures.

         The Parties have exchanged written discovery.

         B. Discovery That Remains to Be Completed

          Due to recent discussions regarding settlement, Plaintiff requested an extension to submit her discovery responses to August 1, 2019.

         Reason Discovery Has Not Been Completed

         The 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

         Further, 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 that end.

         The 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.

         The foregoing constitutes good cause to amend the existing Scheduling Order ...


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