Opinion
2:22-cv-01418-RFB-BNW
07-11-2023
Angela Bangert, Plaintiff, v. SoFi Bank N.A., et al. Defendants.
Michael Kind, Esq. Nevada Bar No.: 13903 KIND LAW 8860 South Maryland Parkway, Suite 106 Matthew M. Loker, Esq. Admitted Pro Hac Vice LOKER LAW, APC Attorney for Plaintiff Angela Bangert
Michael Kind, Esq.
Nevada Bar No.: 13903
KIND LAW
8860 South Maryland Parkway, Suite 106
Matthew M. Loker, Esq.
Admitted Pro Hac Vice
LOKER LAW, APC
Attorney for Plaintiff Angela Bangert
STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER SUBMITTED IN COMPLIANCE WITH LR 26-1(B)
Plaintiff Angela Bangert and Defendant SoFi Bank, N.A. (jointly as the “parties”), by and through their respective counsel, hereby submit this proposed Joint Discovery Plan and Scheduling Order. The parties will request 180 days of discovery as noted below.
Bangert has resolved her claims against Defendants Experian Information Solutions, Inc.; and, Equifax Information Services, LLC.
PROPOSED DISCOVERY PLAN
The parties propose the following discovery plan and scheduling order:
Initial Disclosures
-August 10, 2023
Amend Pleadings and Add Parties
September 10, 2023
Expert Disclosures (Initial)
November 10, 2023
Expert Disclosures (Rebuttal)
December 8. 2023
Discovery Cutoff
January 7, 2024
Dispositive Motions
February 23, 2024
Pretrial Order
May 7, 2024
In the event that dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until 30 days after decision on the dispositive motions or until further order of the court.
Pretrial Disclosures: The disclosures required by Rule 26(a)(3), and any objections thereto, shall be included in the joint pretrial order.
Extensions or Modifications of the Discovery Plan and Scheduling Order: Applications to extend any date set by the discovery plan, scheduling order, or other order must comply with the Local Rules.
Protective Order: The parties may seek to enter a stipulated protective order pursuant to Rule 26(c) prior to producing any confidential documents.
Electronic Service: The parties agree that pursuant to Rules 5(b)(2)(E) and 6(d) of the Federal Rules of Civil Procedure any pleadings or other papers may be served by sending such documents by email.
Alternative Dispute Resolution Certification: The parties certify that they met and conferred about the possibility of using alternative dispute-resolution processes including mediation, arbitration, and early neutral evaluation. The parties have not reached any stipulations at this stage.
Alternative Forms of Case Disposition Certification: The parties certify that they considered consent to trial by a magistrate judge under 28 U.S.C. § 636(c) and Fed.R.Civ.P. 73 and the use of the Short Trial Program (General Order 2013-01). The parties have not reached any stipulations at this stage.
Electronically Stored Information: The parties have discussed the retention and production of electronic data. The parties agree that service of discovery by electronic means, including sending original electronic files by email or on a cd is sufficient. The parties reserve the right to revisit this issue if a dispute or need arises.
Electronic evidence conference certification: The parties further intend to present evidence in electronic format to jurors for the purposes of jury deliberations at trial.
The parties discussed the presentation of evidence for juror deliberations but did not reach any stipulations as to the method at this early stage.
SCHEDULING ORDER
The above-set stipulated Discovery Plan of the parties shall be the Scheduling Order for this action pursuant to Federal Rule of Civil Procedure 16(b) and Local Rule 16-1.
IT IS SO ORDERED.