United States District Court, D. Nevada
PATRICIA A. WILLIAMS, Plaintiff,
ARIA RESORT & CASINO, LLC, a Nevada limited liability company, Defendant.
OFFICES OF ROBERT P. SPRETNAK, Robert P. Spretnak, Esq.,
Attorney for Plaintiff
JACKSON LEWIS, P.C., Lisa A. McClane, Esq, Attorneys for
STIPULATION AND ORDER TO EXTEND DISCOVERY AND
DISPOSITIVE MOTIONS DEADLINES
PATRICIA A. WILLIAMS and Defendant ARIA RESORT & CASINO,
LLC, a Nevada limited liability company, by and through their
counsel of record, by and through their respective counsel of
record, hereby STIPULATE AND AGREE that the current discovery
cutoff date of August 24, 2018, shall be
continued for an additional 30-day period, up to and
including September 24, 2018. This is the
second extension to the discovery period requested in this
matter. Under the terms of the Stipulated Discovery Plan and
Scheduling Order (ECF No. 20) approved by this Court on
January 8, 2018, the discovery cut-off in this matter
originally was set for June 25, 2018. This was extended to
August 24, 2018, by Stipulation and Order to Extend Discovery
and Dispositive Motion Deadlines (ECF No. 27), approved by
this Court on June 11, 2018. . . . .
COMPLETED TO Dated:
a. Plaintiff served her Initial Disclosures on September 5,
b. Plaintiff served “Plaintiffs' First Set Of
Requests For Production Of Documents” on January 30,
2018. Defendant served “Defendant's Responses and
Objections to Plaintiffs' First Set Of Requests For
Production Of Documents” on June 4, 2018.
c. Defendant served its Initial Disclosures on February 21,
2018. Defendant served its First Supplemental
Disclosures on June 4, 2018.
d. On May 22, 2018, the Court approved the “Stipulated
Protective Order Governing Confidential Information”
(ECF No. 25). There had been considerable negotiations over
the precise terms of this stipulation, which delayed
discovery responses from being served.
e. On June 13, 2018, Defendant served on Plaintiff, by United
States mail, (1) Defendant's First Set of
Interrogatories, and (2) Defendant's First Set of
Requests for Production of Documents. The parties have agreed
to extend the deadline for Plaintiff to serve her responses
to these discovery requests to August 1, 2018.
DISCOVERY YET TO BE COMPLETED:
has noticed the deposition of Plaintiff Patricia A. Williams
for August 24, 2018. There may be additional discovery,
including additional deposition, that will need to be
conducted following the conclusion of that deposition.
intends to take the depositions, pursuant to Fed.R.Civ.P.
30(b)(6), of person(s) most knowledgeable about (a) the
suspension and termination of Plaintiff, as referenced in
paragraphs 19(j) and 19(k) of her Complaint; and (b) any and
all investigations into allegations of employee harassment in
Defendant's in-room dining department that may have taken
place in Calendar Year 2015.
REASONS WHY REMAINING DISCOVERY HAS NOT YET BEEN
Plaintiff serves her responses to the written discovery
served on her on June 13, 2018, which the parties agreed to
extend until August 1, 2018, the parties will be able to
undertake a brief deposition schedule. The scheduling of
depositions is being made difficult by the schedule of
Plaintiff's counsel over the next several weeks, primary
due to the fact that he has to file appellate briefs before
the Ninth Circuit in two different cases in the next few
weeks. Also, the ...