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

Filing 220

ORDER Granting 219 Stipulation for Extension of Time re 216 Order (Fourth Request). Proposed Joint Pretrial Order due by 6/4/2020. Signed by Magistrate Judge Cam Ferenbach on 3/5/2020. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4

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

5

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
Defendants.

16
17

Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel of

18

record, hereby stipulate and request that this Court extend the current deadline to file the Joint

19

Pretrial Order in the above-captioned case by seventy-nine (79) calendar days, up to and including

20

June 4, 2020. This Stipulation is the fourth request to extend the joint Pretrial Order deadline in this

21

case.
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,
(Fourth Request)
vs.

22

The good cause reasons for the requested extension are as follows:

23

(1) the parties’ counsel exchanged their proposed exhibit list on January 6, 2019. Both

24

parties exchanged lists that contained tens of thousands of exhibits.

25

submitted a third (3rd) stipulation to extend the trial deadlines because more time was needed for the

26

parties to voluntarily remove exhibits and respond to the same.

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

Thereafter, the parties

27

(2) The parties’ counsel exchanged revised exhibit lists on February 19, 2020. Though the

28

original batch of exhibits has been reduced, there are still tens of thousands of pages of exhibits that
Page 1 of 3

1

can be reduced if the parties have more time to do so. Counsel for all parties have conducted

2

several lengthy telephone conferences in an effort to reduce the total amount of pages and exhibits

3

to be introduced at trial. After several telephone conferences, the parties have agreed that further

4

reductions are warranted. The parties’ counsel have dedicated numerous individuals to the arduous

5

task of reducing and organizing the tens of thousands of documents produced in discovery to a

6

more manageable number for trial.

from their respective lists, to consider stipulations, if any, and to make determinations as to

9

objections for those that remain; and

Facsimile [phone]

10

(4) The parties requested the extension of 79 days because counsel for the parties want to

11

ensure that they have sufficient availability to review documents and information necessary for the

12

Joint Pretrial Order consistent with existing trial and other scheduling commitments.
In support of this Stipulation, the parties have been working together in good faith and have

13

agreed on the following internal deadlines related to the Joint Pretrial Order:

15

1) The parties are to re-disclose proposed exhibits on April 20, 2020.

16

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

17

3) The parties will exchange language to be incorporated into the Joint Pretrial Order on

18

May 21, 2020.

19

4) The parties will conduct a telephone conference on May 28, 2020 to discuss final

20

language to be incorporated into the Pretrial Order and any remaining issues. Should the parties not

21

agree on the final language in the Pretrial Order, the parties have agreed to file individual Pretrial

22

Orders.

5) The parties agree to identify potential deposition transcript designations of unavailable

23
24

28

Telephone [phone]

14

witnesses, parties and 30(b)(6) witnesses sixty (60) days before trial.

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

(3) The parties need more time to voluntarily organize, cull, and/or perhaps remove exhibits

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

7

6) The parties will file the Pretrial Order by June 4, 2020.

25
26

///

27

///

28

///
Page 2 of 3

1

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

2

IT IS SO STIPULATED AND AGREED.

3
4

DATED this 4th day of March, 2020.

DATED this 4th day of March, 2020.

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

5
6
7

9

11
12
13

Telephone [phone]

14
15

DATED this 4th day of March, 2020.
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
__/s/ Molly Rezac _______________________
Molly Malone Rezac, Esq. (#7435)
50 West Liberty Street, Suite 920
Reno, Nevada 89501
Attorney for Defendants

16
17
18
19
20
21

IT IS SO ORDERED.
_________________________________________
UNITED STATES MAGISTRATE JUDGE
3-5-2020
_________________________________________
DATED
28

Facsimile [phone]

10

22
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

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

8

25
26
27
28
Page 3 of 3