United States District Court, D. Nevada
JEFFREY K. ENGLER and KATHERINE M. SENNES-ENGLER, Plaintiffs,
CMG MORTGAGE, INC. D/B/A CMG FINANCIAL, Defendant.
& WYMAN LLP ANDREW A. BAO, ESQ. Attorneys for Defendant
CMG MORTGAGE, INC. D/B/A CMG FINANCIAL
& KRIEGER, LLC SHAWN W. MILLER, ESQ. Attorney for
Plaintiffs JEFFREY K. ENGLER AND KATHERINE M. SENNES-ENGLER
[PROPOSED] STIPULATION AND ORDER TO EXTEND
to Fed.R.Civ.P. 26(f), and Local Rule 26-1, Plaintiffs
Jeffrey K. Engler and Katherine M. Sennes-Engler
(“Plaintiffs”) and CMG Mortgage Inc. d/b/a CMG
Financial (“CMG”) (collectively the
“Parties”), by and through their attorneys,
hereby stipulate to extend discovery deadlines and other
deadlines in the September 9, 2019 Scheduling Order as
parties have exchanged initial and supplemental disclosures.
Plaintiffs propounded written Interrogatories, Request for
Admissions and Request for Documents (“Plaintiffs'
Written Discovery Requests”) to Defendant. Defendant
has responded to Plaintiffs' Written Discovery Requests
and produced documents. CMG's 30(b)(6) deposition has
been noticed and the parties intend to proceed with
deposition if this action is not settled.
discovery responses and at least one deposition.
parties have been diligently litigating this case and are
requesting this extension for good cause because CMG's
30(b)(6) deposition is currently set for November 18, 2019.
Defense counsel has requested this extension from Plaintiffs
counsel due to a family death, causing defense counsel to be
unavailable from November 15th-November
22nd. Furthermore, Plaintiff has proposed a
settlement that involves CMG being required to, amongst other
matters, modify pending mortgage obligations. CMG is in the
process of considering the parameters of such a resolution.
stipulation is made in good faith, is not interposed for
delay, and is not filed for an improper purpose. This is also
the parties' first request for an extension.
Current Discovery Deadlines.
• Discovery Cutoff: January 22, 2020
• Amending Pleadings/Adding Parties: October 24,
• Initial Expert Disclosures and Interim Status Report: