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 \| Telephone: (702) 240-7979 Facsimile: (866) 412-6992 || Attorneys for Plaintiff 9 UNITED STATES DISTRICT COURT | 10 DISTRICT OF NEVADA 1] || SEBASTIAN SYMEONIDES, an Individual, CASE NO. 2:23-cv—00854-JAD-MDC 13 Plaintiff, < VS. || TRUMP RUFFIN COMMERCIAL, LLC, a | STIPULATION AND ORDER TO Foreign Limited-Liability Company d/b/a EXTEND DEADLINE FOR || TRUMP INTERNATIONAL LAS VEGAS and PLAINTIFF’S REPLY BRIEFS TRUMP INTERNATIONAL HOTEL & REGARDING PLAINTIFF’S || TOWER LAS VEGAS; TRUMP RUFFIN | MOTION FOR SANCTIONS DUE TO TOWER I, LLC, a Foreign Limited-Liability DEFENDANTS’ SPOLIATION OF |} Company; TRUMP INTERNATIONAL EVIDENCE [ECF Nos. 90 and 92] HOTELS MANAGEMENT, LLC, a Foreign || 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 the: || respective counsel of record, that the deadline for Plaintiff to file reply briefs to Defendant Trum: || Ruffin Tower I, LLC’s Opposition to Plaintiffs Motion for Sanctions Due to Defendants || Spoliation of Evidence [ECF No. 109] and Defendant Otis Elevator Company’s Points an || Authorities in Response to Plaintiff’s Motion for Sanctions Due to Spoliation of Evidence [EC] || No. 110], currently due May 29, 2025, shall be extended to June 5, 2025.

] The parties respectfully request a one-week extension of the deadline for Plaintiff to fil || reply briefs to Defendants’ oppositions to his Motion for Sanctions Due to Defendants’ Spoliatio: || of Evidence. Good cause exists for this request because the oppositions involve complex lega || and factual issues, and additional time is needed to fully and completely respond to each issue || Properly responding to both oppositions requires a thorough review of extensive records, expet ||reports, deposition testimony, and case law to ensure the Court receives well-reasoned an ||comprehensive arguments. Extending the deadline will ensure adequate time for Plaintiff t ||/research the relevant legal issues and fully respond to the arguments raised in Defendants || opposition briefs, ensuring that the Court has the full context to make an informed decision. | 10 Notably, the parties previously agreed to a two-week extension for Defendants to file thet || oppositions, which the Court approved. ECF No. 108. Plaintiff makes this request in good fait = 12 || and not for purposes of delay, and believes that a brief extension will aid the Court by allowin 2 13 || Plaintiff to prepare thorough and focused reply briefs. No party will be prejudiced by th —!

14 || requested extension.

15 Dated this 28" day of May, 2025 | 16 Respectfully Submitted By: Approved as to Form and Content: || CHRISTIANSEN TRIAL LAWYERS ROGERS, MASTRANGELO, CARALHO & 19 MITCHELL /s/ Keely P. Chippoletti 20 /s/ Su-Lyn Combs PETER S. CHRISTIANSEN, ESQ.

21 || Nevada Bar No. 5254 REBECCA L. MASTRANGELO, ESQ. » R. TODD TERRY, ESQ. Nevada Bar No. 5417 Nevada Bar No. 6519 700 South 3rd Street || KEELY P. CHIPPOLETTI, ESQ. Las Vegas, NV 89101 Nevada Bar No. 13931 || 710 South 7th Street VASUDHSIRI T. SATHIENMARS, ESQ.

95 || Las Vegas, NV 89101 SU-LYN COMBS, ESQ.

Attorneys for Plaintiff TUCKER ELLIS LLP 26 515 South Flower Steet, 42" Floor 4 Los Angeles, CA 90071 Attorneys for Defendant Otis Elevator Co. l Approved as to Form and Content: LEWIS BRISBOIS BISGAARD & SMITH || LLP 4 . . /s/ Yilmaz E. Turkeri 5 □ DAVID B. AVAKIAN, ESQ.

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

Nevada Bar No. 15468 || 6385 South Rainbow Blvd., Suite 600 Las Vegas, NV 89118 Attorneys for Defendant Trump Ruffin Tower .

10 || 4 LLG erroneously sued herein as Trump Ruffin Commercial, LLC, d/b/a Trump || International Vegas and Trump International Hotel & Tower Las Vegas; and Trump |! International Hotels Management, LLC = OB —!

4 14 ORDER ~ IT IS SO ORDERED that the deadline for Plaintiff to file reply briefs to Defendant Trum | Ruffin Tower I, LLC’s Opposition to Plaintiff's Motion for Sanctions Due to Defendants Spoliation of Evidence [ECF No. 109] and Defendant Otis Elevator Company’s Points an Authorities in Response to Plaintiff's Motion for Sanctions Due to Spoliation of Evidence [EC No. 110], currently due May 29, 2025, is hereby extended to June 5, 2025.. > f “p, a — af a a a Unghie Noay etude niteg*Staies Magigtrave Judge 2 PPV 24 tf Jf I 25 L Dated: 5-30-§5