United States District Court, D. Nevada
OFFICES OF MICHAEL P. BALABAN Michael P. Balaban Attorneys
for Plaintiff Rosalind Brown
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., Anthony
L. Martin, Jill Garcia Wells Fargo Tower Suite 1500 Attorneys
for Defendants ResortStay International, LLC, and Starpoint
Resort Group, Inc.
STIPULATION AND ORDER TO EXTEND DISCOVERY AND OTHER
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 April 9, 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. Defendants deposed Plaintiff on
September 13, 2017. Plaintiff deposed Richard Braglia and
Frank Braglia on October 10, 2017.
REMAINING DISCOVERY TO BE COMPLETED
has requested to take the depositions of Shelley Brittell,
Angelica Talamaya, Jessica Carranza-Sanchez, Miranda Cox, Jim
Danz, Brad Benson and Darren Horvath in the near future. The
parties are conferring on these depositions. Additional
written discovery and supplemental document requests might
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.
same time new attorneys have been assigned to this case due
to Erica J. Chee, prior lead associate with Ogletree,
Deakins, Nash, Smoak & Stewart, P.C.
(“Ogletree”), leaving the firm. These new
attorneys, due to the expansiveness of this matter's
record, have needed more time than was anticipated to catch
up and fully understand the issues in this matter.
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 anticipated.
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: