JOINT MOTION FOR EXTENSION OF PRETRIAL DEADLINES 

- Page 1

Daniel P. Mensher, OSB #074636 

Mark A. Griffin (Pro Hac Vice) 

Laura R. Gerber (Pro Hac Vice) 

Lisa Faye Petak (Pro Hac Vice) 

dmensher@kellerrohrback.com 

mgriffin@kellerrohrback.com 

lgerber@kellerrohrback.com 

lpetak@kellerrohrback.com 

Keller Rohrback L.L.P. 

1201 Third Avenue, Suite 3200 

Seattle, WA 98101 

Telephone: (206) 623-1900 

Facsimile: (206) 623-3384 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

DANICA LOVE BROWN, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

STORED VALUE CARDS, INC. (d/b/a NUMI 

FINANCIAL); and CENTRAL NATIONAL 

BANK AND TRUST COMPANY, ENID, 

OKLAHOMA, 

Defendant. 

No. 3:15-cv-1370-MO 

JOINT MOTION FOR EXTENSION 

OF PRETRIAL DISCOVERY DEADLINES 

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure (“Fed. R. Civ. P.”) and 

Local Rule 16-3(a), Plaintiff Danica Love Brown and Defendants Stored Value Cards, Inc. 

(“SVC”) and Central National Bank and Trust (“CNB”), Enid, Oklahoma, hereby respectfully 

move this Court to grant an extension of certain pretrial discovery deadlines. In relevant part, the 

parties request extending the fact discovery deadline and the motion to compel deadline by two 

months, from February 2, 2018 to April 2, 2018, extending the trial expert deadlines by 6 weeks, 

Case 3:15-cv-01370-MO Document 145 Filed 01/09/18 Page 1 of 4
JOINT MOTION FOR EXTENSION OF PRETRIAL DEADLINES - Page 2 

and extending the trial expert depositions by 5 weeks. If this motion is granted, neither the class 

certification motion deadline nor the dispositive motion deadline would be changed. 

The grounds for this motion are as follows: 

1. On June 20, 2017, the Court entered Minutes of Proceedings (Dkt. #140), in 

which the Court adopted Plaintiff’s Proposed Scheduling Order (Dkt. #125). Among other 

things, the scheduling order set forth deadlines for fact and expert discovery and dispositive 

motions. 

2. In order to give the parties sufficient time to complete written fact discovery, 

depositions, and obtain deposition transcripts before expert disclosures or class certification 

briefs are due, the parties respectfully request an extension of certain discovery deadlines 

consistent with the table set out below. As noted above, if this motion is granted, the class 

certification deadline and the dispositive motion deadline would remain unchanged. 

Event Current Deadline Proposed Deadline 

Fact Discovery February 2 April 2 (+2 months)

Motion to Compel Deadline February 23 April 23 (+2 months)

Plaintiff Trial Expert April 6 May 11 (+6 weeks)

Defendant Trial Expert May 4 June 15 (+6 weeks)

Plaintiff Trial Expert Depo May 18 June 22 (+5 weeks)

Defendant Trial Expert June 15 July 20 (+5 weeks)

Plaintiff Class Cert Motion June 1 June 1

Dispositive Motion August 3 August 3

3. The parties have been working diligently and cooperatively to complete written 

discovery in this matter, including negotiating electronic records custodians and electronic 

records search terms, and participating in numerous meet and confers to resolve outstanding 

discovery disputes concerning Plaintiff’s First Request for Production of Documents to Central 

National Bank, and Plaintiffs’ First Request for Production to Defendant Stored Value Cards, 

Inc. 

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JOINT MOTION FOR EXTENSION OF PRETRIAL DEADLINES - Page 3 

4. To date, Defendant CNB has produced to Plaintiffs 40,189 pages of documents. 

Additional documents remain to be produced by Defendant CNB. Defendant SVC has produced 

42,089 pages of documents to Plaintiffs in addition to a voluminous Excel spreadsheet 

containing data. Defendant SVC is in the process of reviewing an additional 75,000 email 

documents for production to Plaintiff and anticipates completing production of those documents 

by the end of January, 2018. 

5. Defendants deposed Plaintiff Danica Brown in September 2017, and on 

December 29, 2017, Defendant Stored Value Card Inc. issued a Request for Production of 

Documents to Plaintiff Brown. 

6. There are currently five depositions scheduled for January of 2018 in this matter, 

including the depositions of Defendant Central National Bank employees Scott Shyrock, Dennis 

Gerhard, and a Rule 30(b)(6) deposition of Defendant Central National Bank during the week of 

January 8, and the depositions of Defendant Stored Value Cards employees Michele Dominguez 

and Karen Mossman during the week of January 22. The parties anticipate noticing additional 

depositions in this matter later this month. 

Respectfully submitted this 9th day of January, 2018. 

KELLER ROHRBACK L.L.P.

By: s/ Laura Gerber 

Daniel Mensher, OSB #074636 

Mark A. Griffin, Pro Hac Vice 

Laura R. Gerber, Pro Hac Vice 

Lisa Faye Petak, Pro Hac Vice 

1201 Third Avenue, Suite 3200 

Seattle, WA 98101-3052 

BENJAMIN HAILE ATTORNEY AT 

LAW 

Benjamin Haile 

P.O. Box 2581 

Portland, OR 97208 

FOX ROTHSCHILD LLP

By: s/ Eric Nystrom ______ 

Eric J. Nystrom, Pro Hac Vice 

222 South 9th Street, Suite 2000 

Minneapolis, MN 55402 

HITT HILLER MONFILS WILLIAMS 

LLP

James L. Hiller, OSB #772220 

411 SW Second Avenue, Suite 400 

Portland, OR 97204 

Attorneys for Central National Bank and 

Trust 

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JOINT MOTION FOR EXTENSION OF PRETRIAL DEADLINES - Page 4 

THE HUMAN RIGHTS DEFENSE 

CENTER 

Sabarish Neelakanta, Pro Hac Vice 

PO Box 1151 

Lake Worth, FL 33460 

GISKAN SOLOTAROFF & 

ANDERSON LLP 

Oren Giskan, Pro Hac Vice Forthcoming 

11 Broadway - Suite 2150 

New York, New York 10004 

Attorneys for Plaintiff 

STINTON LEONARD STREET LLP

By: s/ George Verschelden ______ 

George Verschelden, Pro Hac Vice 

1201 Walnut Street, Suite 2900 

Kansas City, MO 64106 

STINTON LEONARD STREET LLP 

Todd A. Noteboom, Pro Hac Vice 

Andrew S. Scavotto, Pro Hac Vice 

Jeffrey G. Mason, Pro Hac Vice 

50 South 6th Street, Suite 2600 

Minneapolis, MN 55402 

MARKOWITZ HERBOLD PC 

Chad Naso, OSB #150310 

Kerry J. Shepherd, OSB# 944343 

1211 SW Fifth Avenue, Suite 3000 

Portland, OR 97204 

Attorneys for Stored Value Cards, Inc. 

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