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De Quinonez v. Ramparts Inc.

United States District Court, D. Nevada

July 10, 2018

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

          JAMES P. KEMP, ESQ. Nevada Bar No: 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No.: 13382 Attorneys for Plaintiff Maria Mendez de Quinonez

          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. On May 31, 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. 35) which the parties genuinely believed would be sufficient time to complete all remaining discovery.

         This third request arises from the parties sincere belief this matter can be resolved, but additional time is required to do so. The parties began discussions to resolve this matter on June 5, 2018, which has included gathering additional information necessary to resolve this matter fully and completely. The parties continue in their discussions and additional information may be necessary. If this matter does not reach resolution, current outstanding depositions will need to be taken, as well as concluding Plaintiff's deposition on limited topics as was agreed to by respective Counsel.

         4. The parties stipulate and agree to extend the discovery deadline for sixty-one (61) days from July 13, 2018 up to and including August 13, 2018, for the Parties to continue their efforts to resolve this matter and should those efforts be unsuccessful, for purposes of allowing the parties to complete deposition discovery, allow for deposition transcripts to be prepared timely, and to allow for discovery to be completed 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. Depositions have been taken.

         Plaintiff served the following disclosures:

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

         c. Second Supplemental ...


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