Ruisi v. Aramark Sports and Entertainment Services, LLC, No. 2:2020cv01544 - Document 47 (D. Nev. 2021)

Court Description: ORDER granting 45 Stipulation to Extend Discovery Deadlines. Discovery due by 5/17/2021. Motions due by 6/15/2021. Proposed Joint Pretrial Order due by 7/15/2021. If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order. Signed by Magistrate Judge Cam Ferenbach on 1/25/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Ruisi v. Aramark Sports and Entertainment Services, LLC Doc. 47 Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 1 of 6 Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 1 Brooke A. Bohlke Nevada Bar No. 9374 2 Susana Santana Nevada Bar No. 13753 3 WOOD, SMITH, HENNING & BERMAN LLP 2881 Business Park Court, Suite 200 4 Las Vegas, Nevada 89128-9020 Phone: 702 251 4100 ♦ Fax: 702 251 5405 5 bbohlke@wshblaw.com ssantana@wshblaw.com 6 Attorneys for Defendants, ARAMARK SPORTS 7 AND ENTERTAINMENT SERVICES, LLC, ARAMARK CAMPUS, LLC, ARAMARK 8 EDUCATIONAL GROUP, LLC, ARAMARK EDUCATIONAL SERVICES, LLC, 9 ARAMARK SPORTS AND ENTERTAINMENT GROUP, LLC, ARAMARK 10 SERVICES, INC. 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA, SOUTHERN DIVISION 13 14 NATALIE RUISI, Plaintiff, 15 v. 16 19 20 21 22 23 24 STIPULATION AND ORDER TO EXTEND DEADLINES (FIRST REQUEST) Trial Date: 17 18 Case No. 2:20-cv-01544-JCM-VCF None Set ARAMARK SPORTS AND ENTERTAINMENT SERVICES, LLC, a Foreign Limited Liability Company; ARAMARK CAMPUS, LLC, a Foreign Limited Liability Company; ARAMARK EDUCATIONAL GROUP, LLC, a Foreign Limited Liability Company; ARAMARK EDUCATIONAL SERVICES, LLC, a Foreign Limited Liability Company; ARAMARK SPORTS AND ENTERTAINMENT GROUP, LLC, a Foreign Limited Liability Company; ARAMARK SERVICES, INC., a Foreign Corporation; and, ROE Business Organizations I-X; and DOE INDIVIDUALS I-X, Inclusive, Defendants. 25 26 27 / / / 28 / / / 16679509.1:10745-0108 Case No. 2:20-cv-01544 Dockets.Justia.com Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 2 of 6 Pursuant to LR IA 6-1, LR IA 6-2 and LR 26-3, and for good cause shown, Plaintiff 1 2 Natalie Ruisi, and Defendants, ARAMARK SPORTS AND ENTERTAINMENT 3 SERVICES, LLC, ARAMARK CAMPUS, LLC, ARAMARK EDUCATIONAL GROUP, LLC, ARAMARKSERVICES, LLC, ARAMARK SPORTS AND ENTERTAINMENT GROUP, 4 EDUCATIONAL 5 LLC, ARAMARK SERVICES, INC. (herein “the parties”), by and through their respective counsel 6 of record, hereby stipulate and agree to and jointly move this Honorable Court for an order to 7 continue discovery by ninety (90) days as indicated below. This is the first request for an extension 8 of time to complete discovery. This request is being made within 21-days of the expiration of the Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 9 current discovery period set for February 15, 2021. ECF No. 9. 10 A. DISCOVERY COMPLETED TO DATE 11 The parties have produced the following disclosures: 12 1. a. 13 14 Plaintiff served the following disclosures: 2. Initial Disclosures on September 28, 2020. Defendants served the following disclosures: 15 a. Initial Disclosures on September 30, 2020; 16 b. Supplemental Disclosures on November 6, 2020, December 4, 2020, and December 14, 2020. 17 18 The parties have completed the following written discovery: 19 Plaintiff served the following written discovery requests on September 16, 2020: 20 1. 21 Entertainment, LLC. Defendant responded on November 6, 2020 and supplemented 22 its responses on December 14, 2020. 23 2. 24 of Documents to Defendant Aramark Sports and Entertainment, LLC. Defendant responded 25 on November 6, 2020 and supplements its responses on December 14, 2020. 26 Defendant served the following written discovery requests on January 15, 2021: 27 1. Defendant’s First Set of Interrogatories to Plaintiff 28 2. Defendant’s First Set of Requests for Admission to Plaintiff Plaintiff’s First Set of Interrogatories to Defendant Aramark Sports and 16679509.1:10745-0108 Plaintiff’s first set of Requests for Document and First Set of Request for Production -2- Case No. 2:20-cv-01544 Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 3 of 6 1 3. Defendant’s First Set of Request for Production of Documents to Plaintiff. 2 The parties have not taken any depositions. 3 B. DISCOVERY REMAINING TO BE COMPLETED 4 1. Depositions of parties, non-parties, percipient, and corporate witnesses; 5 2. Written discovery; 6 3. Issuance of Subpoenas; 7 4. The parties anticipate that supplemental written discovery may be needed once the 8 parties complete depositions. 9 C. A scheduling order can be modified "for good cause and with the judge's consent." FRCP 11 16(b)(4). "A motion or stipulation to extend time must state the reasons for the extension requested Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 10 REASON FOR REQUEST FOR EXTENSION OF DISCOVERY DEADLINES 12 and must inform the court of all previous extensions of the subject deadline the court granted." LR 13 IA 6-1 (a). "District courts should generally allow amendments of pre-trial orders when 'no 14 substantial injury will be occasioned to the opposing party, the refusal to allow the amendment might 15 result in injustice to the movant, and the inconvenience to the court is slight.'" Campbell Industries 16 v. M/V Gemini, 619 F.2d 24, 27-28 (9th Cir. 1980) (quoting Angle v. Sky Chef, Inc., 535 F.2d 492, 17 495 (9th Cir. 1976); Sherman v. United States, 462 F.2d 577, 579 (5th Cir. 1972)). Here, as discussed 18 below, there is no dispute among the parties that an extension would cause any injury or injustice, 19 and that a refusal of extension could prejudice the parties. Additionally, no trial date is currently set. 20 Therefore, the stipulated request for an extension should be granted. 21 The parties are actively conducting discovery and have engaged in meet and confers to 22 resolve disputes before seeking Court intervention. However, the parties have engaged in motion 23 practice, most recently having appeared before the Court on January 8, 2021 to resolve several 24 discovery disputes. Moreover, COVID-19 has presented additional challenges the parties have had 25 to navigate. The parties agree that this matter should be resolved on the merits. To that end, the 26 parties continue to pursue discovery and their attempts to resolve discovery disputes short of Court 27 intervention. 28 As a result, the parties herein request that the current deadlines be extended by 90 days. The 16679509.1:10745-0108 -3- Case No. 2:20-cv-01544 Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 4 of 6 1 parties are also amenable to participate in a telephonic conference with the Court if necessary, to Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 2 further discuss the bases for the requested 90-day extension of deadlines. 3 D. CURRENT SCHEDULE TO COMPLETE REMAINING DISCOVERY: 4 Rebuttal Expert Disclosures: January 18, 2021 5 Close of Discovery: February 15, 2021 6 Dispositive Motions: March 17, 2021 7 Joint Pre-Trial Order: April 16, 2021 8 E. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 9 Rebuttal Expert Disclosures: April 19, 2021 10 Close of Discovery: May 17, 2021 11 Dispositive Motions: June 15, 2021 12 Joint Pre-Trial Order: July 15, 2021 If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order. 13 / / / 14 / / / 15 / / / 16 / / / 17 / / / 18 / / / 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 16679509.1:10745-0108 -4- Case No. 2:20-cv-01544 Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 5 of 6 1 F. CURRENT TRIAL DATE: 2 No trial is yet scheduled in this matter. A joint proposed pretrial order is due on April 16, 3 2021. The parties seek additional time so that the same proposed pretrial order is due July 15, 2021 4 or 30 days after this Court's ruling on dispositive motions. 5 G. REQUEST NUMBER: 6 This is the first request for an extension of time to complete discovery. Wherefore, the 7 parties respectfully request that the Court grant this request to extend the discovery deadlines as 8 outlined above. IT IS SO STIPULATED. Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 9 10 DATED this 22nd day of January 2021. DATED this 22nd day of January 2021. 11 WOOD, SMITH, HENNING & BERMAN KEMP AND KEMP 12 /s/ Susana Santana By: BROOKE A. BOHLKE Nevada Bar No. 9374 SUSANA SANTANA Nevada Bar No. 13753 2881 Business Park Court, Ste. 200 Las Vegas, Nevada 89128-9020 Tel. 702 251 4100 13 14 15 16 17 /s/ Victoria L. Neal By: JAMES P, KEMP Nevada Bar No. 6375 VICTORIA L. NEAL Nevada Bar No. 13382 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 Tel: 702 258 1183 Attorneys for Defendants, ARAMARK SPORTS AND ENTERTAINMENT SERVICES, LLC, ARAMARK CAMPUS, LLC, ARAMARK EDUCATIONAL GROUP, LLC, ARAMARK EDUCATIONAL SERVICES, LLC, ARAMARK SPORTS AND ENTERTAINMENT GROUP, LLC, ARAMARK SERVICES, INC. 18 19 20 21 Attorneys for Plaintiff, NATALIE RUISI 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 16679509.1:10745-0108 -5- Case No. 2:20-cv-01544 Case 2:20-cv-01544-JCM-VCF Document 47 Filed 01/25/21 Page 6 of 6 ORDER 1 2 HAVING CONSIDERED THE FOREGOING STIPULATION OF COUNSEL, AND 3 GOOD CAUSE APPEARING, THE DISCOVERY DEADLINES ARE AMENDED AS SET 4 FORTH ABOVE. 5 DATED: January 25, 2021. 6 _______________________________ US MAGISTRATE JUDGE CAM FERENBACH 7 8 9 11 Attorneys at Law 2881 BUSINESS PARK COURT, SUITE 200 LAS VEGAS, NEVADA 89128-9020 TELEPHONE 702 251 4100 ♦ FAX 702 251 5405 WOOD, SMITH, HENNING & BERMAN LLP 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16679509.1:10745-0108 -6- Case No. 2:20-cv-01544

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