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).

ERIC L. CRAMER (pro hac vice)
BERGER MONTAGUE PC
1818 Market Street, Suite 3600
Philadelphia, PA 19103
Telephone: [phone]
Facsimile: [phone]
[e-mail]
JOSEPH R. SAVERI (pro hac vice)
JOSEPH SAVERI LAW FIRM, LLP
601 California Street, Suite 1200
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
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: [phone]
Facsimile: [phone]
[e-mail]

CHRISTOPHER S. YATES (Pro hac vice)
[e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111
WILLIAM A. ISAACSON (Pro hac vice)
[e-mail]
JESSICA PHILLIPS (Pro hac vice)
[e-mail]
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: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
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: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Joshua P. Davis
BERGER MONTAGUE PC
505 Montgomery Street, Suite 625
San Francisco, CA 94111
Telephone: [phone]
Email: [e-mail]

BRETTE M. TANNENBAUM (Pro hac vice)
[e-mail]
YOTAM BARKAI (Pro hac vice)
[e-mail]
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP
1285 Avenue of the Americas
New York, NY 10019
CHRISTOPHER S. YATES (Pro hac vice)
[e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111
SEAN M. BERKOWITZ (Pro hac vice)
[e-mail]
LATHAM & WATKINS LLP
330 North Wabash Ave, Suite 2800
Chicago, IL 60611
LAURA WASHINGTON (Pro hac vice)
[e-mail]
LATHAM & WATKINS LLP
10250 Constellation Blvd, Suite 1100
Los Angeles, CA 90067
DAVID L. JOHNSON (Pro hac vice)
[e-mail]
LATHAM & WATKINS LLP
555 Eleventh Street NW, Suite 1000
Washington, D.C. 20004

DONALD J. CAMPBELL (No. 1216)
[e-mail]
J. COLBY WILLIAMS (No. 5549)
[e-mail]
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