Mendez De Quinonez v. MGM Resorts International et al

Filing 33

ORDER Granting 32 First Stipulation to Extend Discovery and Dispositive Motion Deadlines. Discovery due by 6/13/2018. Motions due by 7/13/2018. Proposed Joint Pretrial Order due by 8/13/2018. Signed by Magistrate Judge Peggy A. Leen on 4/6/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02394-RFB-PAL Document 32 Filed 03/30/18 Page 1 of 3

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Elayna J. Youchah
Nevada State Bar No. 5837
Donald P. Paradiso
Nevada State Bar No. 12845
JACKSON LEWIS P.C.
3800 Howard Hughes Pkwy, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Ramparts, Inc. dba Luxor Hotel & Casino

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARIA MENDEZ DE QUINONEZ,
Plaintiff,

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Case No. 2:17-cv-02394-RFB-PAL
STIPULATION AND ORDER TO
EXTEND DISCOVERY AND
DISPOSITIVE MOTION DEADLINES

vs.
RAMPARTS INC., d/b/a LUXOR HOTEL &
CASINO,

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(First Request)

Defendants.

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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.
This is the first request by the parties to amend the Court’s December 15, 2017

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2.

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Scheduling Order.

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3.

The parties stipulate and agree to extend the discovery deadline for thirty (30) days

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from May 14, 2018 up to and including June 13, 2018, for the sole purpose of allowing the parties

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to complete deposition discovery. All written discovery must be served such that responses are

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due no later than May 14, 2018.

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Jackson Lewis P.C.
Las Vegas

Case 2:17-cv-02394-RFB-PAL Document 32 Filed 03/30/18 Page 2 of 3

4.

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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

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The parties have been diligently pursuing discovery. To date, they have exchanged initial

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disclosures, including relevant documents.

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In addition, the parties have exchanged written

document requests and interrogatories.
Plaintiff served the following disclosures:

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a.

Initial Disclosures on November 29, 2017;

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b.

First Supplemental Disclosures on December 19, 2017.

Defendant served the following disclosures:

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a.

Initial Disclosures on November 29, 2017;

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b.

First Supplemental Disclosures on March 8, 2018.

Plaintiff served the following discovery requests:

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a.

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First Set of Request for Production of Documents. Defendant responded

on February 7, 2018.

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b.

First Set of Interrogatories. Defendant responded on February 7, 2018.

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c.

Plaintiff has identified five deposition she seeks to complete.

Defendant served the following discovery requests:

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a.

First Set of Interrogatories. Plaintiff’s response is due on March 30, 2018.

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b.

First Set of Request for Production of Documents. Plaintiff’s response is

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due on March 30, 2018.
c.

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Defendant has set Plaintiff’s deposition for May 9, 2018.

STATEMENT OF DISCOVERY THAT REMAINS TO BE COMPLETED

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The parties are currently in the process of scheduling depositions. To accommodate

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counsel, including third party deponents’ schedules, the parties seek until June 13, 2018 to ensure

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completion of these depositions.

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deadline to complete depositions be extended for thirty (30) days from May 14, 2018 to June 13,

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2018.

Jackson Lewis P.C.
Las Vegas

For the above stated reasons, the parties request that the

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Case 2:17-cv-02394-RFB-PAL Document 32 Filed 03/30/18 Page 3 of 3

PROPOSED SCHEDULE

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The parties stipulate and agree that:

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1.

Discovery: The discovery period shall be extended thirty (30) days from May 14,

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2018 to June 13, 2018, for the sole purpose of allowing the parties to complete deposition

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discovery. All written discovery must be served such that responses are due no later than May 14,

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2018.
2.

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Dispositive Motions: The dispositive motions deadline shall be extended thirty

(30) days from June 13, 2018 to July 13, 2018.
4.

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Pre-Trial Order: If no dispositive motions are filed, the Joint Pretrial Order shall

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be filed thirty (30) days after the date set for the filing of dispositive motions, which is August 13,

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2018. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be

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suspended until thirty (30) days after decision on the dispositive motions or by further order of the

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Court.

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This stipulation and order is sought in good faith and not for the purpose of delay. No
prior request for any extension of scheduling deadlines has been made.
DATED this 30th day of March, 2018.
KEMP & KEMP

JACKSON LEWIS P.C.

/s/ James P. Kemp
James P. Kemp, NV Bar No. 6375
Victoria L. Neal, NV Bar No. 13382
7435 W. Azure Drive, Suite 110
Las Vegas, Nevada 89130

/s/ Elayna J. Youchah
Elayna J. Youchah, NV Bar No. 5837
Donald P. Paradiso, NV Bar No. 12845
3800 Howard Hughes Parkway, Ste. 600
Las Vegas, Nevada 89169

Attorneys for Plaintiff
Maria Mendez De Quinonez

Attorneys for Defendant
Ramparts, Inc. dba Luxor Hotel Casino

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ORDER
IT IS SO ORDERED.

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Jackson Lewis P.C.
Las Vegas

United States District/Magistrate Judge
Date: April 6, 2018
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