Kennedy et al v. Las Vegas Sands Corp. et al

Filing 214

ORDER Granting 213 Stipulation for Extension of Time re 212 Order (Second Request). Proposed Joint Pretrial Order due by 1/17/2020. Signed by Magistrate Judge Cam Ferenbach on 11/26/2019. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5

LAGOMARSINO LAW
ANDRE M. LAGOMARSINO, ESQ. (#6711)
3005 W. Horizon Ridge Pkwy., #241
Henderson, Nevada 89052
[e-mail]
Attorney for Plaintiffs Sean Kennedy, Andrew Snider, Christopher Ward,
Randall Weston and Ronald Williamson
UNITED STATES DISTRICT COURT

6

DISTRICT OF NEVADA

7

9

11
12
13

Telephone [phone]

14

LAS VEGAS SANDS CORP., a Domestic
Corporation; SANDS AVIATION, LLC, a
Domestic Limited-Liability Company;

15
16
17
18
19
20
21
22
23
24

Defendants.
Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of
record, hereby stipulate and request that this Court extend the current deadline to file the Joint
Pretrial Order in the above-captioned case by thirty (30) days, up to including January 17, 2020.
This Stipulation is the second request to extend the joint pretrial order deadline in this case.
The reason for the extension is as follows: (1) the parties have to sort through and analyze
over thirty thousand (30,000) pages of documents to identify exhibits; (2) Plaintiff’s counsel is
28

Facsimile [phone]

10

SEAN KENNEDY, an individual; ANDREW CASE NO.: 2:17-cv-00880-JCM-VCF
SNIDER, an individual, CHRISTOPHER
WARD, an individual; RANDALL WESTON, an
STIPULATION AND ORDER TO
individual; and RONALD WILLIAMSON, an
EXTEND PRETRIAL ORDER
individual;
DEADLINE AND RELATED DEADLINES
Plaintiffs,
(Second Request)
vs.

involved in heavy briefing on a separate matter Farmer v. LVMPD, et al., Case No.: 2:18-cv00860-GMN-VCF that will require him to draft four (4) to six (6) briefs in the next fifteen (15)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

LAGOMARSINO LAW

3005 West Horizon Ridge Parkway, Suite 241, Henderson, Nevada 89052

8

25
26
27
28

days; (3) Plaintiff’s counsel will have to respond to multiple dispositive motions filed in the same
case after December 16, 2019; and (4) Plaintiff’s counsel’s office is short-staffed this week for the
Thanksgiving Holiday (and exhibit exchanges are to take place after the holiday (12/3).
In support of this Stipulation, the parties have agreed on the following internal deadlines

Page 1 of 2

1

related to the joint pretrial order:

2

WHEREAS the parties have agreed on the following deadlines:

3

1) The parties are to exchange proposed exhibits on January 6, 2020.

4

2) The parties are to serve objections to proposed exhibits on January 13, 2020.

5

3) The parties will exchange language to be incorporated into the pretrial order on January

6

15, 2020.

language to be incorporated into the pretrial order and any remaining issues. Should the parties not

9

agree on the final language in the pretrial order, the parties have agreed to file individual pretrial

Facsimile [phone]

10
11
12

orders.
5) The parties agree to identify potential deposition transcript designations of unavailable
witnesses, parties and 30(b)(6) witnesses sixty (60) days before trial.
6) The parties will file the Pre-Trial Order by January 17, 2020.

14

This extension is made in good faith and is not intended for purposes of delay.

15

IT IS SO STIPULATED AND AGREED.

16

DATED this 25th day of November, 2019.

DATED this 25th day of November, 2019.

LAGOMARSINO LAW

DLA PIPER LLP (US)

_/s/ Andre Lagomarsino___________________
Andre M. Lagomarsino, Esq. (#6711)
3005 West Horizon Ridge Parkway, Suite 241
Henderson, Nevada 89052
Attorney for Plaintiffs Sean Kennedy,
Andrew Snider, Christopher Ward,
Randall Weston and Ronald Williamson

___/s/ Mary Dollarhide__________________
Mary Dollarhide, Esq. (admitted pro hac vice)
Chelsea Mutual, Esq. (admitted pro hac vice)
4365 Executive Drive, Suite 1100
San Diego, California 92121
Attorneys for Defendants

17
18
19
20
21
22

28

Telephone [phone]

13

23
24

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

LAGOMARSINO LAW

4) The parties will conduct a telephone conference on January 16, 2020 to discuss final

8
3005 West Horizon Ridge Parkway, Suite 241, Henderson, Nevada 89052

7

IT IS SO ORDERED.

25
26
27
28

_________________________________________
UNITED STATES MAGISTRATE JUDGE
11-26-2019
_________________________________________
DATED
Page 2 of 2