Shipman v. NAV-LVH Casino, LLC

Filing 31

ORDER granting 30 Stipulation; Discovery due by 4/30/2018. Motions due by 5/29/2018. Proposed Joint Pretrial Order due by 6/16/2018. Signed by Magistrate Judge Carl W. Hoffman on 1/9/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:16-cv-02722-JCM-CWH Document 30 Filed 01/08/18 Page 1 of 3

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PHILLIP A. SILVESTRI
Nevada Bar No. 11276
GREENSPOON MARDER, P.A.
3993 Howard Hughes Pkwy, #400
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
MYRNA L. MAYSONET
CHERISH A BENEDICT
(Admitted Pro Hac Vice)
GREENSPOON MARDER, P.A.
201 East Pine St., Suite 500
Orlando, Florida 32801
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MELVIN SHIPMAN,

)
)
)
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Plaintiff,
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vs.
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NAV-LVH CASINO, LLC dba WESTGATE )
)
LAS VEGAS RESORT & CASINO, a Nevada )
Limited Liability Company,
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Defendant.
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)
)

CASE NO. 2:16-cv-02722-JCM-CWH
STIPULATION AND REQUEST TO
EXTEND DISCOVERY AND OTHER
DEADLINES
(Third Request)

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COME NOW, Plaintiff, named above, by and through his counsel of record, MICHAEL P.

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BALABAN, ESQ., and Defendant, named above, by and through its attorneys of record, MYRNA

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L. MAYSONET, ESQ., CHERISH A BENEDICT, ESQ., and PHILLIP A. SILVESTRI, ESQ.,
pursuant to Local Rule 26-4, and herein stipulate, agree and make joint application to extend the

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32209492.1

Case 2:16-cv-02722-JCM-CWH Document 30 Filed 01/08/18 Page 2 of 3

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discovery cut-off and related dates for a period of ninety (90) days up to and including Monday,

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April 30, 2018. The present discovery cut-off date is January 29, 2018, and no calendar call date

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or trial date has been set.

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This request is being made timely in accordance with LR 26-4 and the prior scheduling

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Order, which provides that requests for further discovery extensions must be made no later than

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twenty-one (21) days before the existing discovery cut-off date, or, here, by January 8, 2018. This

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is the third request for an extension.

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To date the parties have both made their initial disclosures to the other side and Defendant
has propounded written discovery to Plaintiff and Plaintiff has propounded written discovery to
Defendant. In addition, Defendant intends to depose Plaintiff, and Plaintiff intends to depose Kit

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Quirante, Frank D’Agati, Dan Piccolo, Carolyn McKay, Rolando Betuicci, Robert Stubson and
Raymond Lujan, who are mostly former employees of Defendant and need to be located and
contacted. In addition, counsel for both parties have other cases before this Court, which involve
overlapping witnesses to some extent and, thus, the attorneys for both parties are coordinating the

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scheduling of the depositions in such cases to minimize the burden on the witnesses and travel for

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out-of-state counsel.

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The parties and their attorneys have diligently worked to complete discovery as

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expediently as possible and will continue to try to complete the remaining discovery in as

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expedient a manner as possible.

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Given the above, the parties request that the discovery period be extended as follows:

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Activity

Former Date

Requested Date

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Discovery Cut-Off Date

01/29/18

04/30/18

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Dispositive Motions

02/26/18

05/29/18

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Pretrial Order

03/28/18

06/26/181

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Or 30 days after the decision on the last dispositive motion.

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Case 2:16-cv-02722-JCM-CWH Document 30 Filed 01/08/18 Page 3 of 3

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In accordance with LR 26-4 the parties understand that any further requests for discovery
extensions must be made no later than twenty-one (21) days before the new proposed discovery
cut-off date of April 30, 2018, or no later than twenty-one (21) days before any other deadline

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sought to be extended.

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DATED this 8th day of January, 2018.

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Law Offices of Michael P. Balaban

Greenspoon Marder

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/s/ Michael P. Balaban
Michael P. Balaban, Esq.
Nevada Bar No. 9370
Law Offices of Michael P. Balaban
10726 Del Rudini Street
Las Vegas, NV 89141
Tel: [phone]
Fax: [phone]

/s/ Myrna L. Maysonet
MYRNA L. MAYSONET
Florida Bar No.: 0429650
CHERISH A BENEDICT
Florida Bar No. 99073
201 East Pine Street, Suite 500
Orlando, FL 32801
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant

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Attorneys for Plaintiffs

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Phillip A. Silvestri, Esq.
Nevada Bar No. 11276
GREENSPOON MARDER
3993 Howard Hughes Pkwy., Ste. 400
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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IT IS SO ORDERED

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_________________________________
UNITED STATES DISTRICT JUDGE
MAGISTRATE
JUDGE

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January 9, 2018
DATED: ______________

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