Kraja v. Bellagio, LLC et al

Filing 232

ORDER Granting 231 Stipulation re 227 MINUTES OF PROCEEDINGS. Evidentiary Hearing set for 1/3/2020 at 01:00 PM in LV Courtroom 6C before Judge Andrew P. Gordon. See Order for further deadlines. Signed by Judge Andrew P. Gordon on 10/9/2019. (Copies have been distributed pursuant to the NEF - ADR)

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Todd L. Bice, Esq., Bar No. 4534
[e-mail]
Robert A. Ryan, Bar No. 12084
[e-mail]
PISANELLI BICE PLLC
400 South 7th Street, Suite 300
Las Vegas, NV 89101
Telephone: [phone]

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Attorneys for Defendant, Bellagio, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

PISANELLI BICE PLLC 
400 SOUTH 7TH STREET, SUITE 300 
LAS VEGAS, NEVADA  89101 

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ANDI KRAJA, an individual;

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Case No. 2:15-cv-01983-APG-NJK

Plaintiff,

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vs.

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JOINT STATUS
REPORT/STIPULATION FOR
PROPOSED SCHEDULE

BELLAGIO, LLC, a Nevada Corporation;
VINCENT ROTOLO, an individual; ROE
Business Organizations I-X; and DOE
INDIVIDUALS I-X, Inclusive,

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ORDER

Defendants.

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On September 26, 2019, this Court held a hearing on Defendant Bellagio, LLC’s

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(“Bellagio”) Renewed Motion for Judgment as a Matter of Law; or in the Alternative, for a New

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Trial (the “Motion”). At the hearing, based upon the Court’s review of the Motion, the Opposition

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filed by Plaintiff, Andi Kraja (“Kraja”) and Bellagio’s Reply and following oral argument from the

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parties, the Court ordered the parties to meet and confer regarding the scheduling of an evidentiary

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hearing on Bellagio’s Motion, including a schedule for possible discovery prior to the same.

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Following the hearing, the parties have met and conferred and hereby file the following Joint Status

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Report/Proposed Schedule:

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1.

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The parties shall be entitled to serve written discovery limited to the evidence

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surrounding the iPhone used by Kraja to take the photograph introduced at trial as Trial Exhibit 1,

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along with the availability of any potential iCloud or other electronic backups of said photograph

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(the “Photograph At Issue”). Any such written discovery shall be served by October 18, 2019.

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The parties reserve the right to seek additional written discovery, even after this deadline, should

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good cause exist for such additional discovery.
2.

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Kraja shall have until November 8, 2019 to retain and disclose an expert report

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regarding the Visual Evidence. Kraja reserves the right to seek additional time to retain and disclose

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an expert report, should the need for such an extension arise.
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The parties shall have until December 20, 2019 to take the deposition of the opposing

party’s expert.
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The evidentiary hearing shall be held on January 3, 2020 at 1:00 p.m. The

PISANELLI BICE PLLC 
400 SOUTH 7TH STREET, SUITE 300 
LAS VEGAS, NEVADA  89101 

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evidentiary hearing shall be limited to four (4) hours.

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DATED this 8th day of October, 2019.

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PISANELLI BICE PLLC

KEMP & KEMP

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By:
/s/ Todd L. Bice
Todd L. Bice, Esq., Bar No. 4534
Robert A. Ryan, Esq., Bar No. 12084
400 South 7th Street, Suite 300
Las Vegas, Nevada 89101

By: /s/ James P. Kemp
James P. Kemp, Esq., Bar No. 6375
Victoria L. Neal, Esq., Bar No. 13382
7435 W. Azure Drive, Suite 110
Las Vegas, Nevada 89130

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Attorneys for Defendant, Bellagio LLC

Attorneys for Plaintiff, Andi Kraja

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IT IS SO ORDERED:

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________________________________
DISTRICT COURT DISTRICT JUDGE
UNITED STATES JUDGE
Dated: October 9, 2019.

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DATED: ___________________

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