| || JEFFREY L. HOGUE (SBN 234557) TYLER J. BELONG (SBN 234543) 2 || HOGUE & BELONG 3555 5" Avenue, Suite 300 3 || San Diego, CA 92103 Phone: (619) 238-4720 4||Fax: (619) 238-5260 5 || Attorneys for Plaintiff and all others similarly situated, 6||R. ERNEST MONTANARI (SBN 152209) MICHELLE C, JACKSON (SBN 170898) 7 || TREVOR B. MCCANN (SBN 243724) COLLINS & COLLINS LLP 8 || 2175 N California Boulevard, Suite 835 Walnut Creek, CA 94596 9 || Phone: (510) 844-5100 Fax: (510) 844-5101 10 Attorneys for Defendant APARTMENT 11 | MANAGEMENT CONSULTANTS, LLC. 12 B UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO 15 16 ROSA NAVARRO, individually and on behalf | Case No. 3:24-cv-06829-AMO of all others similarly situated; and ROES 1 [Hon. Araceli Martinez-Olguin] 17 |] through 100 inclusive, JOINT STIPULATION TO CONTINUE 18 Plaintiff, DISCOVERY CUTOFF AND EXPERT 19 DISCLOSURE DEADLINES v. 20 APARTMENT MANAGEMENT oo 21 || CONSULTANTS, LLC, a Utah limited Complaint Filed: December 8, 2022 liability company; and DOES 1 through 100, Trial Date: December 8, 2026 22 |! inclusive, a Defendants. 24 25 26 a7 28 JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF AND EXPERT DISCLOSURE DEADLINES
1 L INTRODUCTION 2 Plaintiffs Rosa Navarro and Nihla Olsem, individually and on behalf of all others similarly 3 situated ("Plaintiffs"), and Defendant Apartment Management Consultants, LLC ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby submit this
6 Joint Stipulation to Continue the Discovery Cutoff and Expert Disclosure and Cutoff Deadlines (the 7 || "Joint Stipulation") and respectfully request that the Court grant the relief set forth herein. 8 Il. PROCEDURAL BACKGROUND 9 This is a putative class action that was originally filed in state court on December 8, 2022, 10 and was removed to this Court on September 27, 2024. On April 17, 2025, the Court held a case management conference at which both Parties appeared through their respective counsel of record.
B The Parties have since engaged in ongoing discovery, so they can be in position to mediate and to 14 || brief the motion for class certification. Its As part of the discovery process, the Parties have engaged in extensive meet-and-confer 16} efforts regarding the discovery and production of records, including, without limitation, (i) the Class M7 List (i.e., contact information for the putative class); (ii) all moveout records for a representative 10% sample group of tenant moveouts (i.c., all records provided to putative class members to
20 substantiate all deductions to their security deposit at time of moveout; this includes, without 41 || lumitation, all moveout statements, purchase orders, upon moveout); (iii) all records requested 22 || regarding the late fees charged to the 10% sample group of putative class members; and (iv) other 23 requested documents — e.g., tenant dispute correspondence regarding amounts allegedly withheld a from their security deposits and/or their late fees, and electronic database{s) containing information about if and when Defendant received and/or paid vendor invoices. (See, e.g., Dkt 47.) 97 Defendant maintains that it timely produced all records according to the Court’s Order on 9g || Response Deadline (Dkt. 47). Plaintiffs dispute Defendant’s position and maintain that Defendant — GON ono CE OO
| || produced one of three sets of electronic records in March 2026, not in December 2025. Regardless, 2 there is no dispute that Defendant's electronic records have now been produced. However, for those records Defendant maintains in paper format only, there is a dispute. Defendant maintains that it “produced” them to Plaintiff pursuant to Federal Rule of Civil 6 Procedure, Rule 34, by informing Plaintiffs that they can go to Defendant’s dozens of different 7 || apartment complexes and retrieve and copy the paper records at a then-estimated cost of more than 8 || $1 Million. (See Jackson v. United Artists Theatre Circuit, Inc., 278 F.R.D. 586 (2011); see also ? I Chambers v. Whirlpool Corporation, 290 F.3d 645 (2020)) Plaintiffs dispute that Defendant’s offer qualifies as “production” of the responsive paper records. Accordingly, once this dispute became 11 apparent, the parties began extensively meeting and conferring on this issue for the past several 13 months. Through these efforts, the parties have identified vendors that are believed to be able to 14 || Scan and provide the extensive responsive paper records at a fraction of the original estimated cost, 15} but the parties need additional time to vet the third-party vendors and cost estimates, in order to 16 || determine if a stipulation can be reached. Importantly, the electronically stored responsive records do not include any of the invoices, 18 receipts, bills or other substantiating records that Defendant alleges it sent to the vacating tenants in 19 20 the sample group. Such records are directly relevant to the crux of the claims and defenses in this 21 || lawsuit and, according to Defendant, such records are maintained only in hard copy (i.e., paper) 22 || form, thus - according to the latest vendor estimates received in the last week — will cost 23 approximately hundreds of thousands of dollars to scan so Plaintiffs can review them. 24 : 2 The parties have been and continue to diligently meet and confer over the scope of these 25 crucial hard copy records. The parties meet and confer efforts have been via email, telephone and 26 07 via zoom video conference. Their meet and confer process has necessitated, among other things, 2g || obtaining various vendor estimates for the scanning of the paper records and negotiations among the
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| || parties toward a potential resolution. The parties anticipate they will either reach an agreement or 2 impasse within the next 2 weeks. If they reach an impasse, the parties will promptly file a joint discovery motion with the Court pursuant to the Court’s rules. Regardless whether the parties reach a stipulation or impasse within the next two weeks, they 6 will need a significant amount of additional time within which to complete discovery of these hard 7 || copy records — including having a vendor physically retrieve and scan these paper records, allow 8 || counsel time to analyze all of those records, allow the parties’ experts time to analyze the records, 9 and time to prepare and exchange expert reports. Additionally, once the document production is Mi complete, the parties will need to complete depositions of Plaintiffs and of Defendant's Rule 30(b)(6) ; witnesses and key employees, among other discovery. 3 The parties presently anticipate that once a stipulation is reached or a Court order is entered 14 |] to resolve the present dispute over cost, timing and scope of production of the responsive paper 15}; records, the parties will need approximatety at teast 60 days for a third-party vendor to scan and 16 produce all of the records, and another 90 days for the parties and their experts to review and prepare m expert reports regarding these crucial records. The currently calendared deadlines relevant to this Stipulation are as follows:
20 e April 30, 2026: Expert Designation Cutoff; 4 e June 30, 2026: Discovery Cutoff; 39 e October |, 2026: Motion for Class Certification Filing Deadline; 73 © October 15,2026: Opposition to Motion for Class Certification Filing Deadline; 44 e October 23, 2026: Reply in support of Motion for Class Certification Filing Deadline; 25 e November 19, 2026: Hearing on Motion for Class Certification. 36 Based on all of the foregoing, the parties agree that they need to continue the Expert 27 || Designation deadline and the Discovery Cutoff. However, they do not presently foresee the need to 28 || continue the Motion for Class Certification hearing and briefing schedule. oi.
l IV.
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| || JEFFREY L. HOGUE (SBN 234557) TYLER J. BELONG (SBN 234543) 2 || HOGUE & BELONG 3555 5" Avenue, Suite 300 3 || San Diego, CA 92103 Phone: (619) 238-4720 4||Fax: (619) 238-5260 5 || Attorneys for Plaintiff and all others similarly situated, 6||R. ERNEST MONTANARI (SBN 152209) MICHELLE C, JACKSON (SBN 170898) 7 || TREVOR B. MCCANN (SBN 243724) COLLINS & COLLINS LLP 8 || 2175 N California Boulevard, Suite 835 Walnut Creek, CA 94596 9 || Phone: (510) 844-5100 Fax: (510) 844-5101 10 Attorneys for Defendant APARTMENT 11 | MANAGEMENT CONSULTANTS, LLC. 12 B UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO 15 16 ROSA NAVARRO, individually and on behalf | Case No. 3:24-cv-06829-AMO of all others similarly situated; and ROES 1 [Hon. Araceli Martinez-Olguin] 17 |] through 100 inclusive, JOINT STIPULATION TO CONTINUE 18 Plaintiff, DISCOVERY CUTOFF AND EXPERT 19 DISCLOSURE DEADLINES v. 20 APARTMENT MANAGEMENT oo 21 || CONSULTANTS, LLC, a Utah limited Complaint Filed: December 8, 2022 liability company; and DOES 1 through 100, Trial Date: December 8, 2026 22 |! inclusive, a Defendants. 24 25 26 a7 28 JOINT STIPULATION TO CONTINUE DISCOVERY CUTOFF AND EXPERT DISCLOSURE DEADLINES
1 L INTRODUCTION 2 Plaintiffs Rosa Navarro and Nihla Olsem, individually and on behalf of all others similarly 3 situated ("Plaintiffs"), and Defendant Apartment Management Consultants, LLC ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby submit this
6 Joint Stipulation to Continue the Discovery Cutoff and Expert Disclosure and Cutoff Deadlines (the 7 || "Joint Stipulation") and respectfully request that the Court grant the relief set forth herein. 8 Il. PROCEDURAL BACKGROUND 9 This is a putative class action that was originally filed in state court on December 8, 2022, 10 and was removed to this Court on September 27, 2024. On April 17, 2025, the Court held a case management conference at which both Parties appeared through their respective counsel of record.
B The Parties have since engaged in ongoing discovery, so they can be in position to mediate and to 14 || brief the motion for class certification. Its As part of the discovery process, the Parties have engaged in extensive meet-and-confer 16} efforts regarding the discovery and production of records, including, without limitation, (i) the Class M7 List (i.e., contact information for the putative class); (ii) all moveout records for a representative 10% sample group of tenant moveouts (i.c., all records provided to putative class members to
20 substantiate all deductions to their security deposit at time of moveout; this includes, without 41 || lumitation, all moveout statements, purchase orders, upon moveout); (iii) all records requested 22 || regarding the late fees charged to the 10% sample group of putative class members; and (iv) other 23 requested documents — e.g., tenant dispute correspondence regarding amounts allegedly withheld a from their security deposits and/or their late fees, and electronic database{s) containing information about if and when Defendant received and/or paid vendor invoices. (See, e.g., Dkt 47.) 97 Defendant maintains that it timely produced all records according to the Court’s Order on 9g || Response Deadline (Dkt. 47). Plaintiffs dispute Defendant’s position and maintain that Defendant — GON ono CE OO
| || produced one of three sets of electronic records in March 2026, not in December 2025. Regardless, 2 there is no dispute that Defendant's electronic records have now been produced. However, for those records Defendant maintains in paper format only, there is a dispute. Defendant maintains that it “produced” them to Plaintiff pursuant to Federal Rule of Civil 6 Procedure, Rule 34, by informing Plaintiffs that they can go to Defendant’s dozens of different 7 || apartment complexes and retrieve and copy the paper records at a then-estimated cost of more than 8 || $1 Million. (See Jackson v. United Artists Theatre Circuit, Inc., 278 F.R.D. 586 (2011); see also ? I Chambers v. Whirlpool Corporation, 290 F.3d 645 (2020)) Plaintiffs dispute that Defendant’s offer qualifies as “production” of the responsive paper records. Accordingly, once this dispute became 11 apparent, the parties began extensively meeting and conferring on this issue for the past several 13 months. Through these efforts, the parties have identified vendors that are believed to be able to 14 || Scan and provide the extensive responsive paper records at a fraction of the original estimated cost, 15} but the parties need additional time to vet the third-party vendors and cost estimates, in order to 16 || determine if a stipulation can be reached. Importantly, the electronically stored responsive records do not include any of the invoices, 18 receipts, bills or other substantiating records that Defendant alleges it sent to the vacating tenants in 19 20 the sample group. Such records are directly relevant to the crux of the claims and defenses in this 21 || lawsuit and, according to Defendant, such records are maintained only in hard copy (i.e., paper) 22 || form, thus - according to the latest vendor estimates received in the last week — will cost 23 approximately hundreds of thousands of dollars to scan so Plaintiffs can review them. 24 : 2 The parties have been and continue to diligently meet and confer over the scope of these 25 crucial hard copy records. The parties meet and confer efforts have been via email, telephone and 26 07 via zoom video conference. Their meet and confer process has necessitated, among other things, 2g || obtaining various vendor estimates for the scanning of the paper records and negotiations among the
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| || parties toward a potential resolution. The parties anticipate they will either reach an agreement or 2 impasse within the next 2 weeks. If they reach an impasse, the parties will promptly file a joint discovery motion with the Court pursuant to the Court’s rules. Regardless whether the parties reach a stipulation or impasse within the next two weeks, they 6 will need a significant amount of additional time within which to complete discovery of these hard 7 || copy records — including having a vendor physically retrieve and scan these paper records, allow 8 || counsel time to analyze all of those records, allow the parties’ experts time to analyze the records, 9 and time to prepare and exchange expert reports. Additionally, once the document production is Mi complete, the parties will need to complete depositions of Plaintiffs and of Defendant's Rule 30(b)(6) ; witnesses and key employees, among other discovery. 3 The parties presently anticipate that once a stipulation is reached or a Court order is entered 14 |] to resolve the present dispute over cost, timing and scope of production of the responsive paper 15}; records, the parties will need approximatety at teast 60 days for a third-party vendor to scan and 16 produce all of the records, and another 90 days for the parties and their experts to review and prepare m expert reports regarding these crucial records. The currently calendared deadlines relevant to this Stipulation are as follows:
20 e April 30, 2026: Expert Designation Cutoff; 4 e June 30, 2026: Discovery Cutoff; 39 e October |, 2026: Motion for Class Certification Filing Deadline; 73 © October 15,2026: Opposition to Motion for Class Certification Filing Deadline; 44 e October 23, 2026: Reply in support of Motion for Class Certification Filing Deadline; 25 e November 19, 2026: Hearing on Motion for Class Certification. 36 Based on all of the foregoing, the parties agree that they need to continue the Expert 27 || Designation deadline and the Discovery Cutoff. However, they do not presently foresee the need to 28 || continue the Motion for Class Certification hearing and briefing schedule. oi.
l IV. GOOD CAUSE FOR CONTINUANCE 2 Good cause exists to continue the Discovery Cutoff and Expert Disclosure Deadlines and for 3 . the following reasons: First, the parties have made diligent efforts to conduct discovery and have made significant g || Progress toward resolving their outstanding discovery dispute regarding the production of the 7 || indispensable paper records (7.e., moveout records such as invoices, receipts, bills, purchase orders, 8 || rate sheets, etc.) — the Parties have met and conferred no fewer than 20 times via email, telephone ? || and, most recently, via Zoom. However, despite diligent efforts from both parties, the dispute — while narrowed — is not yet fully resolved and, accordingly, Plaintiffs have not yet received copies o 11 the responsive paper records. 12 13 Second, the discovery dispute at issue involves detailed questions regarding the scope, [4 || method, timing, and cost of the retrieval, scanning and production of the hard copy records for a sample group from a large class of putative class. The parties, therefore, require further time to see □□□ 16 they can informally resolve this issue or to have the Court weigh-in on the appropriate means of 17 ok resolving it. 18 Third, regardless of whether the parties reach an informal resolution or a Court-influenced 19 20 resolution in the next three weeks, they will still need a substantial amount of additional time to 2] |] actually retrieve, scan, review and allow experts time to analyze and prepare reports because these 22 || records are all saved in hard copy only. 23 Fourth, the requested continuance is not only essential but modest given the amount of work involved in obtaining and reviewing the voluminous paper records; 25 Fifth, the requested extension of the Expert Exchange and Discovery Cutoff Deadlines will 26 37 not cause a continuance of any other dates or deadlines in this case and will not unduly delay the 2 || resolution of this matter.
l Sixth, the continuance will allow the Parties the additional time necessary to resolve the - impasse, complete the necessary document production, conduct the remaining discovery, and prepare for class certification briefing and mediation. Without this additional time neither party will be prepared to mediate or brief the class certification issue. V. JOINT STIPULATION 7 Based on the foregoing, the Parties hereby stipulate and agree, subject to Court approval, as 8 || follows: 9 1. The Expert Disclosure and Cutoff Deadline is hereby continued to August 15, 2026. 10 , 2. The Discovery Cutoff Deadline is hereby continued to September 30, 2026.
3. The Parties will continue to meet and confer in good faith to resolve the outstanding 12 3 document production issues and any other discovery-related matters. 14 4. Ifthe Parties are unable to resolve their disputes through the meet-and-confer process, they 5 will promptly seek the Court's assistance through the appropriate procedures. 16 VI. CONCLUSION 17 : □□ me For the foregoing reasons, the Parties respectfully request that the Court approve this Joint 18 Stipulation and enter an order continuing the Discovery Cutoff and Expert Disclosure and Cutoff 19 20 Deadlines as set forth above. ae 2 Dated: March@§, 2026 HOGUE & BELONG C ZS 22 By: TYLER J. BELONG 23 JEFFREY L. HOGUE 2A Attorneys for Plaintiffs 25 Dated: March 25, 2026 COLLINS & COLLINS LLP 26 By: <7/et Mantapt TREVOR B. MCCANN 27 R. ERNEST MONTANARI 28 MICHELLE C. JACKSON Attorneys for Defendant -5-
ORDER 3 Upon stipulation of the parties, with good cause appearing, IT IS HEREBY ORDERED 4 || that expert disclosure and discovery cutoff deadlines are continued to August 15, 2026 and 5 || September 30, 2026, respectively. All other dates and deadlines remain unaltered. ’ IT IS SO ORDERED. 9 = 10 DATED:_ 3/31/2026 ( hy acek- Med . HONORABLE ARACELI MARTINEZ-OLGUIN Lil 12 13 14 - 15
16 17 18 19 20 21 a2 a3 24 25 26 27 28 6.