Symeonides v. Trump Ruffin Commercial LLC

Opinion

1 || PETER S. CHRISTIANSEN, ESQ. Nevada Bar No. 5254 2 || pete@christiansenlaw.com R. TODD TERRY, ESQ. 3 || Nevada Bar No. 6519 tterry@christiansenlaw.com 4 || KEELY P. CHIPPOLETTI, ESQ. Nevada Bar No. 13931 5 || keely@christiansenlaw.com CHRISTIANSEN TRIAL LAWYERS 6 || 710 South 7 Street, Suite B Las Vegas, Nevada 89101 7 \| Telephone: (702) 240-7979 Facsimile: (866) 412-6992 8 || Attorneys for Plaintiff 9 UNITED STATES DISTRICT COURT | 10 DISTRICT OF NEVADA 1] 12 || SEBASTIAN SYMEONIDES, an Individual, CASE NO. 2:23-cv—00854-JAD-MDC 13 Plaintiff, < VS. 14 15 || TRUMP RUFFIN COMMERCIAL, LLC, a | STIPULATION AND ORDER TO Foreign Limited-Liability Company d/b/a EXTEND DEADLINE FOR 16 || TRUMP INTERNATIONAL LAS VEGAS and PLAINTIFF’S REPLY BRIEFS TRUMP INTERNATIONAL HOTEL & REGARDING PLAINTIFF’S 17 || TOWER LAS VEGAS; TRUMP RUFFIN | MOTION FOR SANCTIONS DUE TO TOWER I, LLC, a Foreign Limited-Liability DEFENDANTS’ SPOLIATION OF 18 |} Company; TRUMP INTERNATIONAL EVIDENCE [ECF Nos. 90 and 92] HOTELS MANAGEMENT, LLC, a Foreign 19 || Limited-Liability Company; OTIS ELEVATOR CORPORATION, a Foreign Corporation; DOES 20 || I through X, inclusive; and ROE BUSINESS ENTITIES I through XX inclusive, 21 Defendants. 22 23 IT IS HEREBY STIPULATED AND AGREED, by all parties, by and through the: 24 || respective counsel of record, that the deadline for Plaintiff to file reply briefs to Defendant Trum: 25 || Ruffin Tower I, LLC’s Opposition to Plaintiffs Motion for Sanctions Due to Defendants 26 || Spoliation of Evidence [ECF No. 109] and Defendant Otis Elevator Company’s Points an 27 || Authorities in Response to Plaintiff’s Motion for Sanctions Due to Spoliation of Evidence [EC] 28 || 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 2 || reply briefs to Defendants’ oppositions to his Motion for Sanctions Due to Defendants’ Spoliatio: 3 || of Evidence. Good cause exists for this request because the oppositions involve complex lega 4 || and factual issues, and additional time is needed to fully and completely respond to each issue 5 || Properly responding to both oppositions requires a thorough review of extensive records, expet 6 ||reports, deposition testimony, and case law to ensure the Court receives well-reasoned an 7 ||comprehensive arguments. Extending the deadline will ensure adequate time for Plaintiff t 8 ||/research the relevant legal issues and fully respond to the arguments raised in Defendants 9 || 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 11 || 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 17 Respectfully Submitted By: Approved as to Form and Content: 18 || 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 23 || KEELY P. CHIPPOLETTI, ESQ. Las Vegas, NV 89101 Nevada Bar No. 13931 24 || 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. 28

l Approved as to Form and Content: LEWIS BRISBOIS BISGAARD & SMITH 3 || LLP 4 . . /s/ Yilmaz E. Turkeri 5 □ DAVID B. AVAKIAN, ESQ. 6 || Nevada Bar No. 9502 7 YILMAZ E. TURKERI, ESQ. Nevada Bar No. 15468 8 || 6385 South Rainbow Blvd., Suite 600 Las Vegas, NV 89118 9 Attorneys for Defendant Trump Ruffin Tower . 10 || 4 LLG erroneously sued herein as Trump Ruffin Commercial, LLC, d/b/a Trump 11 || International Vegas and Trump International Hotel & Tower Las Vegas; and Trump 12 |! International Hotels Management, LLC = OB —! 4 14 ORDER 15 ~ IT IS SO ORDERED that the deadline for Plaintiff to file reply briefs to Defendant Trum 16 | Ruffin Tower I, LLC’s Opposition to Plaintiff's Motion for Sanctions Due to Defendants 17 Spoliation of Evidence [ECF No. 109] and Defendant Otis Elevator Company’s Points an 18 Authorities in Response to Plaintiff's Motion for Sanctions Due to Spoliation of Evidence [EC 19 No. 110], currently due May 29, 2025, is hereby extended to June 5, 2025.. 20 > 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 26 27 28