United States District Court, D. Nevada
OFFICES OF MICHAEL P. BALABAN Michael P. Balaban Attorneys
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Anthony L.
Martin Erica J. Chee Attorneys for Defendants.
STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER
DEADLINES (FOURTH REQUEST)
ResortStay International, LLC and Starpoint Resort Group,
Inc. (collectively, “Defendants”) and Plaintiff
Rosalind Brown (“Plaintiff”), by and through
undersigned counsel, hereby stipulate and request that the
discovery cut off (currently set for January 8, 2018), as
well as related dates, be extended for a period of ninety
(90) days. This request is submitted pursuant to LR 6-1, 6-2,
7-1 and 26-4 and is the parties' fourth request.
DISCOVERY COMPLETED TO DATE
served their Initial Disclosures on or about April 18, 2017.
Plaintiff served her Initial Disclosures on or about May 11,
2017. Plaintiff served her Requests for Production of
Documents and Interrogatories on or about August 7, 2017.
Defendants' responded to these discovery requests on
October 5, 2017. The parties have been meeting and conferring
as to supplemental responses.
deposed Plaintiff on September 13, 2017. Plaintiff deposed
Richard Braglia and Frank Braglia on October 10, 2017.
REMAINING DISCOVERY TO BE COMPLETED
will be taking the depositions of Shelley Brittell, Angelica
Talamayan, Jessica Carranza-Sanchez and Miranda Cox in
January 2018. They were originally scheduled for December 13,
2017, but end of the year scheduling conflicts have caused
the parties to continue them. Plaintiff also intends to
depose other former and current employees, but dates to do so
have not yet been determined based on the other deponents
schedules. Additional written discovery and supplemental
document requests will also be completed by the parties.
REASONS DISCOVERY CANNOT BE COMPLETED WITHIN THE
the parties have worked diligently to satisfy the current
discovery deadlines, it is unlikely that all required
discovery and requested depositions can be completed within
the current discovery deadline. Some of the witnesses are out
of state and former employees, and the parties are working
with their schedules. Moreover, it has been difficult to
schedule some of the remaining depositions of former
employees that reside in and out of the state of Nevada due
to the holiday season and convention schedule.
parties have been meeting and conferring as to responses to
written discovery and supplemental responses. Defendants are
performing additional searches, but the process has taken
longer than necessary.
REVISED PROPOSED DISCOVERY PLAN
discovery in this case will be conducted in accordance with
the Federal Rules of Civil Procedure and applicable Local
Rules of this District Court. The parties propose to the
Court the following cut-off dates:
A. Discovery Cut-Off Date: The discovery
cut-off deadline shall be Monday, April 9,
2018 (ninety-one days after the current deadline, as