Le et al v. Zuffa, LLC

Filing 967

ORDER Granting in Part the 964 Stipulated Pretrial Schedule. Pretrial Conference set for 3/4/2024 at 09:00 AM in LV Courtroom 7C before Judge Richard F. Boulware II. Calendar Call set for 4/9/2024 at 09:00 AM in LV Courtroom 7C before Judge Richard F. Boulware II. Counsel/Parties are instructed to see the Order for specific deadlines and changes. Signed by Judge Richard F. Boulware, II on 2/5/2024. (Copies have been distributed pursuant to the NEF - DRS) (Additional attachment(s) added on 2/5/2024: # 1 JERS instructions) (DRS).

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ERIC L. CRAMER (pro hac vice) BERGER MONTAGUE PC 1818 Market Street, Suite 3600 Philadelphia, PA 19103 Telephone: (215) 875-3000 Facsimile: (215) 875-4604 ecramer@bm.net JOSEPH R. SAVERI (pro hac vice) JOSEPH SAVERI LAW FIRM, LLP 601 California Street, Suite 1200 San Francisco, California 94108 Telephone: (415) 500-6800 Facsimile: (415) 395-9940 jsaveri@saverilawfirm.com RICHARD A. KOFFMAN (pro hac vice) COHEN MILSTEIN SELLERS & TOLL, PLLC 1100 New York Ave., N.W., Suite 500, East Tower Washington, DC 20005 Telephone: (202) 408-4600 Facsimile: (202) 408 4699 rkoffman@cohenmilstein.com CHRISTOPHER S. YATES (Pro hac vice) chris.yates@lw.com LATHAM & WATKINS LLP 505 Montgomery Street, Suite 2000 San Francisco, CA 94111 WILLIAM A. ISAACSON (Pro hac vice) wisaacson@paulweiss.com JESSICA PHILLIPS (Pro hac vice) jphillips@paulweiss.com PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 2001 K Street, NW Washington, DC 20006 DONALD J. CAMPBELL J. COLBY WILLIAMS CAMPBELL & WILLIAMS 710 South Seventh Street, Ste. A Las Vegas, NV 89101 Telephone: (702) 382-5222 Facsimile: (702) 382-0540 Email: djc@cwlawlv.com Email: jcw@cwlawlv.com Counsel for the Class and Attorneys for All Individual and Representative Plaintiffs Attorneys for Defendant Zuffa, LLC [Additional Counsel Listed on Signature Page] [Additional Counsel Listed on Signature Page] 19, 2024 Order (ECF No. 961), the Parties have met and conferred and submit the below proposed pre-trial schedule. The proposed pre-trial schedule includes proposed deadlines for trial briefs and pre-trial motions, and proposed dates for pre-trial status conferences to coordinate and resolve disputes, at which the Court may conduct a pre-trial evidentiary hearing addressing exhibits and expert testimony anticipated to be used at trial. See id. Date Fri., February 2 Thur., February 8 Mon., February 12 Mon., February 12 Event Parties exchange initial witness lists and deposition designations Parties exchange exhibit lists Parties exchange exhibits Parties exchange initial lists of motions in limine each side plans to raise in advance meet and confer. (To the extent that either party may in good faith determine after February 12 that certain additional motions in limine become necessary, each side may add a certain number of additional motions in limine to its respective list after Trial Briefs are filed.) Thur., February 15 Parties exchange proposed juror questionnaires Fri., February 16 Parties meet and confer regarding motions in limine Mon., February 19 Parties exchange objections to proposed juror questionnaires Tues., February 20 Last day for parties to meet and confer regarding proposed juror questionnaire Wed., February 21 Parties submit proposed juror questionnaire to Court Thur., February 22 Parties exchange exhibit list objections, identification of duplicate exhibits, and rebuttal exhibit lists and exhibits Thur., February 22 Trial Briefs due Fri., February 23 Parties exchange deposition counters, deposition objections, and witness objections Mon., February 26 Parties exchange revised lists of motions in limine that each side plans to raise Mon., February 26 Parties exchange responses to objections to exhibit list, responses to identification of duplicate exhibits, and objections to rebuttal exhibits Mon., February 26 Parties exchange proposed fact stipulations Wed., February 26 Parties meet and confer regarding revised motions in limine Wed., February 26 Parties exchange objections to deposition counters, responses to objections to affirmative deposition designations, and deposition counter-counters Wed., February 26 Parties exchange responses to objections to rebuttal exhibits Mon., March 4 @ 9 am Pretrial Conference 9:00 a.m. Date February 28th by Noon February 28th Thur., March 7 Tues., March 12 March 13 Mon., April 1 Tues., March 19 Thur., March 21 Mon., March 25 Thur., March 28 Mon., April 1 Fri., April 5 Event Witness lists, joint and disputed exhibit lists, deposition designations, and courtesy flash drives due to Court Motions in limine due by Noon Parties exchange responses to proposed fact stipulations Parties exchange proposed jury instructions and verdict form and voir dire Oppositions to motions in limine due Parties submit joint pre-trial order per Local Rule 16-3(b) Parties exchange stipulation for addressing exhibit and deposition designations issues at trial, including proposals for exchange of demonstratives and schedule of witnesses to be called Potential date for hearing or status conference Potential date for hearing or status conference Potential date for hearing or status conference Combined proposed jury instructions, verdict form, and voir dire submitted to the Court 1006 summaries due. Parties agree to make a good-faith effort to disclose all 1006 summaries by this date. With good cause shown, Parties may disclose 1006 summaries after this date if the late disclosure was due in whole or material part to information becoming evident only after the disclosure deadline, provided such summaries are disclosed ten (10) calendar days prior to use at trial. Parties reserve their rights to object to a 1006 summary prior to its use at trial. April 5th Final witness lists, exhibit lists, and courtesy flash drives due to the Court. Exhibits to the Clerk also due this date, as stated below. Tues., April 9 @ 9:00 a.m Calendar Call Mon., April 15 Trial begins The proposed scheduling order is adopted by this Court with the changes noted in red. Parties are advised Exhibits must be marked and submitted electronically in accordance with JERS instructions that will be attached to this order. Dated the 5th day of February, 2024 IT IS SO ORDERED: __________________________ RICHARD F. BOULWARE, II United States District Judge Respectfully submitted, Joseph R. Saveri (pro hac vice) Kevin E. Rayhill (pro hac vice) Christopher K. L. Young (pro hac vice) Itak Moradi (pro hac vice) JOSEPH SAVERI LAW FIRM, LLP 601 California St., Suite 1000 San Francisco, CA 94108 Telephone: +1 (415) 500-6800 Facsimile: +1 (415) 395-9940 Email: jsaveri@saverilawfirm.com Email: krayhill@saverilawfirm.com Email: cyoung@saverilawfirm.com Email: imoradi@saverilawfirm.com Eric L. Cramer (admitted pro hac vice) Patrick F. Madden (admitted pro hac vice) Najah Jacobs (admitted pro hac vice) BERGER MONTAGUE PC 1818 Market St., Suite 3600 Philadelphia, PA 19103 Telephone: +1 (215) 875-3000 Email: ecramer@bm.net Email: mdellangelo@bm.net Email: pmadden@bm.net Email: njacobs@bm.net Joshua P. Davis BERGER MONTAGUE PC 505 Montgomery Street, Suite 625 San Francisco, CA 94111 Telephone: +1 (415) 906-0684 Email: jdavis@bm.net BRETTE M. TANNENBAUM (Pro hac vice) btannenbaum@paulweiss.com YOTAM BARKAI (Pro hac vice) ybarkai@paulweiss.com PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, NY 10019 CHRISTOPHER S. YATES (Pro hac vice) chris.yates@lw.com LATHAM & WATKINS LLP 505 Montgomery Street, Suite 2000 San Francisco, CA 94111 SEAN M. BERKOWITZ (Pro hac vice) sean.berkowitz@lw.com LATHAM & WATKINS LLP 330 North Wabash Ave, Suite 2800 Chicago, IL 60611 LAURA WASHINGTON (Pro hac vice) laura.washington@lw.com LATHAM & WATKINS LLP 10250 Constellation Blvd, Suite 1100 Los Angeles, CA 90067 DAVID L. JOHNSON (Pro hac vice) david.johnson@lw.com LATHAM & WATKINS LLP 555 Eleventh Street NW, Suite 1000 Washington, D.C. 20004 DONALD J. CAMPBELL (No. 1216) djc@campbellandwilliams.com J. COLBY WILLIAMS (No. 5549) jcw@campbellandwilliams.com CAMPBELL & WILLIAMS 700 South 7th Street Las Vegas, Nevada 89101 CERTIFICATE OF SERVICE I hereby certify that the foregoing [Proposed] Joint Stipulated Pre-Trial Schedule was served on January 26, 2024 who have enrolled in this ECF system. /s/ Christopher K.L. Young ____ Christopher K.L. Young

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