United States District Court, D. Nevada
& KEMP James P. Kemp, NV Bar No. 6375 Victoria L. Neal,
NV Bar No. 13382 Attorneys for Plaintiff Maria Mendez De
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
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
5. The parties further agree to extend the due date for
dispositive motions to thirty (30) days after the proposed
new close of discovery.
OF DISCOVERY THAT HAS BEEN COMPLETED
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.
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 ...