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Mamunes v. The Signature Condominiums LLC

United States District Court, D. Nevada, Southern Division

April 3, 2017

DINA MAMUNES, Plaintiff,
v.
THE SIGNATURE CONDOMINIUMS, LLC dba THE SIGNATURE AT MGM GRAND, a Nevada Domestic Limited-Liability Company, DOES 1 through 10; and ROE CORPORATIONS 1 through 10, inclusive, Defendants.

          Darrell D. Dennis, Esq. Steven B. Abbott, Esq. Blake A. Doerr, Esq. LEWIS BRISBOIS BISGAARD & SMITH, LLP Attorneys for Defendant, THE SIGNATURE CONDOMINIUMS, LLC

          REMMEL LAW FIRM JONATHAN T. REMMEL, ESQ. Attorney for Plaintiff, DINA MAMUNES

          PLAINTIFF DINA MAMUNES' MOTION TO EXTEND DISCOVERY DEADLINES

         Plaintiff Dina Mamunes (“Plaintiff”), by and through her attorney, JONATHANT T. REMMEL, ESQ. of the REMMEL LAW FIRM, hereby submits her Motion to Extend Discovery Deadlines. This Motion will likely be unopposed as the parties were discussing a stipulation to extend the discovery deadlines; however, Defense Counsel left for personal vacation before the Stipulation was formally agreed to, thereby requiring the filing of this Motion to meet the 21 day deadline for filing. This Motion is made pursuant to the provisions of Local Rule 26-4 which provides for an extension of discovery upon a showing of good cause, and excusable neglect, present in circumstances such as those at issue here. This is the first request for an extension of discovery made in this case.

         MEMORANDUM OF POINTS AND AUTHORITIES

         I. INTRODUCTION

         The discovery cut off in this matter is May 26, 2017. The current deadline for initial expert disclosures is March 27, 2017. Plaintiff resides in Colorado, along with a majority of her treating physicians. To date, it has been difficult for the parties to obtain records from these out-of-state medical providers. Once the records are obtained, it will also be necessary to submit the same to medical experts for review and consideration. Once the records are secured, the parties may also desire to set the depositions of these providers. However, due existing trial schedules, vacations and other calendaring conflicts, Plaintiff (and presumably the defense) will likely be unable to meet the existing deadlines.

         The parties were able to confer on March 3, 2017 regarding the issue, but were unable to formalize a stipulation regarding this brief extension of discovery before Defense counsel left for vacation. Notwithstanding, and in an abundance of caution, Plaintiff submits this motion for a 60 day extension of all discovery deadlines pursuant to FRCP l6(b)(4), FRCP 26 and Local Rule 26-4 in order to best ensure there is enough time for both parties to adequately prepare for the pending initial expert discovery deadline.

         A. Discovery Conducted to Date

         On August 29, 2016, the parties conducted the Rule 26(f) meeting. The parties have exchanged initial and (several) supplemental Rule 26 disclosures. Each party has propounded initial written discovery requests-- including interrogatories, request to produce, and request for admissions. The parties have conducted a site inspection, along with non-destructive testing. The Defendant has taken the deposition of Plaintiff.

         B. Remaining Discovery

         Discovery to be completed includes:

• Deposition of remaining fact witnesses;
• Deposition of defendants' Rule 30(b)(6) ...

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