Symeonides v. Trump Ruffin Commercial LLC

1 || PETER S. CHRISTIANSEN, ESQ.

Nevada Bar No. 5254 > || [email protected] R. TODD TERRY, ESQ.

3 || Nevada Bar No. 6519 [email protected] || KEELY P. CHIPPOLETTI, ESQ.

Nevada Bar No. 13931 || [email protected] CHRISTIANSEN TRIAL LAWYERS || 710 South 7" Street, Suite B Las Vegas, Nevada 89101 7 Telephone: (702) 240-7979 Facsimile: (866) 412-6992 || Attorneys for Plaintiff 9 UNITED STATES DISTRICT COURT | 10 DISTRICT OF NEVADA || SEBASTIAN SYMEONIDES, an Individual; | CASE NO. 2:23-cv—00854-JAD-VCF 13 Plaintiff, VS. 1s || TRUMP RUFFIN COMMERCIAL, LLC, a | STIPULATION AND ORDER TO Foreign _Limited-Liability Company d/b/a | EXTEND OPPOSITION DEADLINES || ERUMP INTERNATIONAL LAS VEGAS and | TO DEFENDANT OTIS ELEVATOR | TRUMP INTERNATIONAL HOTEL & | COMPANY’S MOTIONS || TOWER LAS VEGAS; TRUMP RUFFIN | TOWER I, LLC, a Foreign Limited-Liability | || Company; TRUMP INTERNATIONAL | HOTELS MANAGEMENT, LLC, a Foreign | ECE No. 59 || Limited-Liability Company; OTIS ELEVATOR | , CORPORATION, a Foreign Corporation; DOES | || I through X, inclusive; and ROE BUSINESS | ENTITIES I through XX inclusive, Defendants.

23 IT IS HEREBY STIPULATED AND AGREED, by all parties, by and through thei || respective counsel of record, that the deadlines for Plaintiff to file oppositions to Defendant Oti || Elevator Company’s Motion to Exclude John Koshak’s Expert Opinion (ECF No. 53), currenth || due January 27, 2025, and Otis Elevator Company’s Motion for Summary Judgment, currenth || due February 3, 2025 (ECF No. 54), shall both be extended to February 17, 2025.

28 Defendant Otis Elevator Company filed a Motion to Exclude John Koshak’s □□□□□ || Opinion [Dkt. #53] and a Motion for Summary Judgment [Dkt. #54] on January 13, 2025 || Defendant Trump Ruffin Tower I, LLC filed Joinders to both motions [Dkt. #56 and #58].

3 The parties agreed to consolidate and extend the deadlines for Plaintiff to oppose th {| motion for summary judgment and the motion to exclude John Koshak. Good cause exists for thi || request because both the motion for summary judgment and the motion to exclude involv || complex legal and factual issues that are interrelated. Properly addressing these motions require || a thorough review of extensive records, expert reports, deposition testimony, and case law t || ensure the Court receives well-reasoned and comprehensive arguments. The issues raised in th || motion for summary judgment and the motion to exclude are closely intertwined. Extending th | 10 || deadlines will allow Plaintiff to present consistent and cohesive arguments, avoiding redundane: ||and ensuring that the Court has the full context to make an informed decision. Aligning th || briefing deadlines for these motions will promote efficiency for all parties and the Court b || consolidating overlapping efforts and ensuring all relevant arguments are presented in a unifie < & || manner.

15 This requested extension is made in good faith, and not for the purposes of delay. | 16 Dated this 23rd day of January, 2025 / Respectfully Submitted By: Approved as to Form and Content: 1) CHRISTIANSEN TRIAL LAWYERS ROGERS, MASTRANGELO, CARALHO & MITCHELL || /Keely Chippoletti /s/ Su-Lyn Combs PETER S. CHRISTIANSEN, ESQ. REBECCA L. MASTRANGELO, ESQ.

22 || Nevada Bar No. 5254 Nevada Bar No. 5417 R. TODD TERRY, ESQ. 700 South 3rd Street Nevada Bar No. 6519 Las Vegas, NV 89101 || KEELY P. CHIPPOLETTI, ESQ.

Nevada Bar No. 13931 VASUDHSIRI T. SATHIENMARS, ESQ.

25 || 710 South 7th Street SU-LYN COMBS, ESQ.

26 Las Vegas, NV 89101 TUCKER ELLIS LLP Attorneys for Plaintiff 515 South Flower Steet, 42"4 Floor 27 Los Angeles, CA 90071 28 Attorneys for Defendant Otis Elevator Co. I Approved as to Form and Content: LEWIS BRISBOIS BISGAARD & SMITH || LLP /s/ Yilmaz Turkeri || DAVID B. AVAKIAN, ESQ.

Nevada Bar No. 9502 || YILMAZ E. TURKERI, ESQ.

7 || Nevada Bar No. 15468 6385 South Rainbow Blvd., Suite 600 || Las Vegas, NV 89118 Attorneys for Defendant Trump Ruffin Tower || 1 LLC, erroneously sued herein as Trump | 10 || Ruffin Commercial, LLC, d/b/a Trump | International Vegas and Trump International || Hotel & Tower Las Vegas; and Trump D International Hotels Management, LLC = x 13 14 ORDER < 5 Based on the parties' stipulation [ECF No. 59] and good cause appearing, IT IS ORDERED that the deadlines to oppose the motion to exclude John Koshak's Expert Opinion || [ECF No. 53] and the motion for summary judgment [ECF No. 54] are extended to February | 17, 2025. | 17 ir 18 / 19 U.S. District Judge Jennifer A. Dorsey 20 Dated: January 28, 2025