1 || Gustavo Ponce, Esq Nevada Bar No. 15084 2 || Mona Amini, Esq. Nevada Bar No. [5381 3 | KAZEROUNI LAW GROUP, APC 6787 W. Tropicana Ave., Suite 250 4 ||Las Vegas, Nevada 89103 Telephone: (800) 400-6808 5 | Facsimile: (800) 520-5523 E-mail: [email protected] 6 || E-mail: [email protected] 7 || Attorneys for Plaintiff, FAIT, TP RELIG i 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA FAITHB. KELII, Case No.: 2:23-cv-01091-JCM-EJY ojo < 12 Plaintiff, = STIPULATION AND REQUEST FO > 1 vs. ORDER TO EXTEND DISCOVERY DEADLINES MONARCH RECOVERY S15 MANAGEMENT, INC. Defendant. [THIRD REQUEST] 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiff FAITH B. KELII (“Plaintiff”) and Defendant MONARCH 2 || RECOVERY MANAGEMENT, INC.(“Defendant’’) (jointly the “Parties”) hereby 3 | jointly! move to extend all deadlines set forth in the Second Stipulation and Request 4 || for Order to Extend Discovery Deadlines filed with this Court on February 26, 2024, 5 || (ECF No. 26) by a period of ninety (90) days pursuant to LR IA 6-1(a) and LR 26-3. 6 || This stipulation is made in good faith and not for purposes of delay. 7 The Parties have cooperated in good faith toward meeting their discovery 8 || obligations, including through the exchange of an initial set of discovery requests but 9 | there have been some unforeseen medical complications that have arisen in the 10 | aftermath. The requested extension will allow the Parties to potentially discuss ||resolution as well as allow the Parties to adequate time to conduct discovery if a < 12 || resolution is not obtained. The Parties have conferred and agree that this brief = 13 || extension is the most reasonable, most economical, and least burdensome way to 14 || proceed with discovery in this case at this moment in time. 15 | 1. DISCOVERY COMPLETED 16 1. A stipulated protective order was submitted to the Court on November 30, 17 2023. 18 2. Plaintiff submitted her initial FRCP 26.1 disclosures on November 6, 2023. 19 3. Defendant submitted its initial FRCP 26.1 disclosures on November 7, 2023. 20 4. Plaintiff has served written discovery requests and received responses 21 |lthereto. The parties are currently meeting and conferring regarding Defendant’s 22 || responses. 23 5. Defendant has served written discovery requests and received responses 24 thereto. The parties are currently meeting and conferring regarding Defendant’s 25 || responses. 26 6. Defendant has noticed the deposition of Plaintiff, but the parties are in the 27 28 |, Defendants Experian Information Solutions, Inc., Trans Union, LLC, and Equifax Information Services, Inc., do not join in this motion because they have settled with Plaintiff.

1 || middle of discussing new deposition dates. 2 | TI. DISCOVERY THAT REMAINS TO BE COMPLETED 3 1. The depositions of the Parties and expert witnesses. 4 2. Additional written discovery, as necessary. 5 3. Expert discovery, including initial and expert disclosures. 6 4. The potential deposition of the original creditor via subpoena. 7 5. Documentary discovery in the form of document demands and subpoenas 8 || duces tecums. 9 6. Any additional discovery as necessary. 10 | TW. REASONS SUPPORTING THE REQUESTED EXTENSION The parties respectfully submit, pursuant to Local Rule 26-3, that good cause < 12 | exists for the following requested extension. This request for an extension of time is = 13 | not sought for any improper purpose or other purpose of delay. Rather, the parties 14 | seek this extension solely for the purpose of allowing sufficient time to conduct = |/discovery in light of the fact that there has been some unforeseen medical = 16 || emergencies with Plaintiff's family that have complicated the timing of this matter, 17 | and additional time is needed for the Parties to make appropriate and efficient 18 | arrangements to alleviate the pending discovery and litigation matters. 19 No party will be prejudiced by this Court granting this Stipulation as all Parties 20 || jointly seek an extension of these deadlines. Moreover, the Parties believe that 21 || allowing the extension will serve the ends of judicial economy. Moreover, the 22 || requested extensions are not sought for the purposes of delay. The Parties believe this 23 ||extension will in fact help with the discovery as well as any disagreements without 24 || prejudicing either Party. This is the Parties’ third request to extend these deadlines. 25 The Parties have been diligent and have been cooperating in good faith 26 || between each other. A request to extend deadlines in the Court's scheduling order 27 || must be supported by a showing of good cause for the extension. LR 26-3; see also 28 || Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). The "good

1 || cause" inquiry focuses mostly on the movant's diligence. Coleman v. Quaker Oats 2 ||Co.,

(9th Cir. 2000). Good cause to extend a discovery 3 || deadline exists "if it cannot reasonably be met despite the diligence of the party 4 || seeking the extension." Johnson,

. IV. PROPOSED SCHEDULE FOR COMPLETING REMAINING 6 |] DISCOVERY 7 The following 1s a list of the current discovery deadlines and the parties’ 8 || proposed extended deadlines:

13 ||/// 19 ||/// 20 21 22 23 24 25 26 27 28

1 WHEREFORE, Plaintiff and Defendant, respectfully request this Honorable 2 Court (1) extend discovery in the present matter as set forth above; and (2) reissue a 3 || new Scheduling Order to reflect the requested extension. 4 5 || Dated: May 22, 2024 Dated: May 22, 2024 6 | KAZEROUNI LAW GROUP, APC GORDON REES SCULLY MANSUKHANI 7 8 By: /s/ Gustavo Ponce By: /s/ Sean Flynn 9 || Gustavo Ponce, Esq. Sean P. Flynn, Esq. Mona Amini, Esq. 1. East Liberty St., Ste. 424 10 16787 W. Tropicana Ave., Ste. 250 Reno, NV 89501 Las Vegas, NV 89103 Attorneys for Defendant Attorneys for Plaintiff MONARCH RECOVERY MANAGEMENT, INC. 12

> 13

14 ORDER = 15 ITJS SO ORDERED: <= 16 . 17 UNITED STA [AGISTRATE JUDGE 18 DATED: May 22, 2024 19 20 21 22 23 24 25 26 27 28