Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Brown v. Resortstay International, LLC

United States District Court, D. Nevada

December 11, 2017

ROSALIND BROWN, Plaintiff,
v.
RESORTSTAY INTERNATIONAL, LLC, a Nevada Limited Liability Company; STARPOINT RESORT GROUP, INC., A Nevada Corporation, Defendant.

          LAW OFFICES OF MICHAEL P. BALABAN Michael P. Balaban Attorneys for Plaintiff.

          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)

         Defendants 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.

         I. DISCOVERY COMPLETED TO DATE

         Defendants 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.

         Defendants deposed Plaintiff on September 13, 2017. Plaintiff deposed Richard Braglia and Frank Braglia on October 10, 2017.

         II. REMAINING DISCOVERY TO BE COMPLETED

         Plaintiff 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.

         III. REASONS DISCOVERY CANNOT BE COMPLETED WITHIN THE DEADLINE

         Although 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.

         The 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.

         IV. REVISED PROPOSED DISCOVERY PLAN

         All 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 the ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.