Filed: Jul. 24, 2019
Latest Update: Jul. 24, 2019
Summary: STIPULATION AND ORDER TO EXTEND TIME (FIRST REQUEST) GEORGE FOLEY, JR. , Magistrate Judge . 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 de
Summary: STIPULATION AND ORDER TO EXTEND TIME (FIRST REQUEST) GEORGE FOLEY, JR. , Magistrate Judge . 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 dea..
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STIPULATION AND ORDER TO EXTEND TIME
(FIRST REQUEST)
GEORGE FOLEY, JR., Magistrate Judge.
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 pursuant to LR 26-4 as requested below.
C. Proposed Schedule for Completion of Discovery
Event Existing Deadline Proposed Deadline
Amendment of Pleadings February 26, 2019
Expert Disclosures May 17, 2019
Interim Status Report April 19, 2019
Rebuttal Expert Disclosures June 14, 2019
Close of Discovery July 19, 2019
Dispositive Motions August 16, 2019 September 15, 2019
Joint Pre-Trial Order January 13, 2020
IT IS HEREBY STIPULATED AND AGREED by and between the Parties to extend the schedule for dispositive deadline as provided herein.
The Parties respectfully request the Court "so-order" this Stipulation
Dated this 23rd day of July, 2019
CRAIG K. PERRY & ASSOCIATES
By: /s/Craig K. Perry
Craig K. Perry, Esq.
3450 West Cheyenne Avenue, Suite 400
North Las Vegas, NV 89032
Attorneys for Plaintiff
Millie Phung Shiu
Dated this 23rd day of July, 2019
CLARK HILL PLLC
By: /s/Jeremy J. Thompson
Nicholas M. Wieczorek, Esq.
Jeremy J. Thompson, Esq.
3800 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89169
Attorneys for Defendant
Equifax Information Services LLC
IT IS SO ORDERED.
