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Brown v. Resortstay International, LLC

United States District Court, D. Nevada

March 20, 2018

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 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 DEADLINES

         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 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.

         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 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.

         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.

         At the 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.

         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 anticipated.

         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 ...


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