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Williams v. Aria Resort & Casino, LLC

United States District Court, D. Nevada

July 20, 2018

PATRICIA A. WILLIAMS, Plaintiff,
v.
ARIA RESORT & CASINO, LLC, a Nevada limited liability company, Defendant.

          LAW OFFICES OF ROBERT P. SPRETNAK, Robert P. Spretnak, Esq., Attorney for Plaintiff

          JACKSON LEWIS, P.C., Lisa A. McClane, Esq, Attorneys for Defendant

          STIPULATION AND ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES

         Plaintiff 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. . . . .

         1.DISCOVERY COMPLETED TO Dated:

a. Plaintiff served her Initial Disclosures on September 5, 2017.
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.[1] 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.

         2. DISCOVERY YET TO BE COMPLETED:

         Defendant 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.

         Plaintiff 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.

         3. REASONS WHY REMAINING DISCOVERY HAS NOT YET BEEN COMPLETED:

         Once 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.[2] Also, the ...


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