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Quinonez v. Ramparts Inc.

United States District Court, D. Nevada

May 24, 2018

MARIA MENDEZ DE QUINONEZ, Plaintiff,
v.
RAMPARTS INC., d/b/a LUXOR HOTEL & CASINO, Defendants.

          KEMP & KEMP James P. Kemp, NV Bar No. 6375 Victoria L. Neal, NV Bar No. 13382 Attorneys for Plaintiff Maria Mendez De Quinonez

          JACKSON LEWIS P.C. Elayna J. Youchah, NV Bar No. 5837 Donald P. Paradiso, NV Bar No. 12845 Attorneys for Defendant Ramparts, Inc. dba Luxor Hotel Casino

          STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES

         The parties, by and through their respective counsel of record, hereby stipulate and agree as follows:

1. On December 15, 2017, this Court entered an Order granting the Stipulated Discovery Plan and Scheduling Order submitted by the parties (ECF No. 27).
2. On April 9, 2018, this Court entered an Order granting the parties' joint Stipulation to Extend Discovery and Dispositive Motion deadlines for a period of 30 days to allow the parties to complete deposition discovery only (ECF No. 33), which the parties genuinely believed would be sufficient time to complete all remaining discovery.
3. This is the second request by the parties to extend discovery. This second request arises from delay caused by the failure to the Social Security Administration to respond timely to a properly served subpoena, as well as dates available for certain witnesses, in conjunction with counsel's schedule, leading to an inability to complete discovery by June 13, 2018. Further, even if the parties were able to complete deposition discovery by June 13, 2018, it is very unlikely that deposition transcripts would be prepared to meet the dispositive motion deadline in time.
4. The parties stipulate and agree to extend the discovery deadline for thirty (30) days from June 13, 2018 up to and including July 13, 2018, for the purposes of allowing the parties to complete deposition discovery, allow for deposition transcripts to be prepared timely, and to allow for discovery to be complete prior to the filing of dispositive motions.
5. The parties further agree to extend the due date for dispositive motions to thirty (30) days after the proposed new close of discovery.

         STATEMENT OF DISCOVERY THAT HAS BEEN COMPLETED

         The parties have been diligently pursuing discovery. To date, they have exchanged initial disclosures, including relevant documents, supplemented their initial disclosures, exchanged written document requests and interrogatories, and responded to the same. Plaintiff has noticed the depositions of several fact witnesses and Defendant has noticed the deposition of Plaintiff. The parties are working collaboratively to schedule further depositions.

         Plaintiff served the following disclosures:

a. Initial Disclosures on November 29, 2017; b. First Supplemental Disclosures on December 19, 2017.
c. Second Supplemental Disclosures on March ...

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