Kennedy et al v. Las Vegas Sands Corp. et al
Filing
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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)
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LAGOMARSINO LAW
ANDRE M. LAGOMARSINO, ESQ. (#6711)
3005 W. Horizon Ridge Pkwy., #241
Henderson, Nevada 89052
aml@lagomarsinolaw.com
Attorney for Plaintiffs Sean Kennedy, Andrew Snider, Christopher Ward,
Randall Weston and Ronald Williamson
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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Telephone (702) 383-2864
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LAS VEGAS SANDS CORP., a Domestic
Corporation; SANDS AVIATION, LLC, a
Domestic Limited-Liability Company;
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Defendants.
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Pursuant to LR IA 6-1 and LR 26-4, the parties, by and through their respective counsel of
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record, hereby stipulate and request that this Court extend the current deadline to file the Joint
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Pretrial Order in the above-captioned case by seventy-nine (79) calendar days, up to and including
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June 4, 2020. This Stipulation is the fourth request to extend the joint Pretrial Order deadline in this
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case.
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Facsimile (702) 383-0065
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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.
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The good cause reasons for the requested extension are as follows:
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(1) the parties’ counsel exchanged their proposed exhibit list on January 6, 2019. Both
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parties exchanged lists that contained tens of thousands of exhibits.
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submitted a third (3rd) stipulation to extend the trial deadlines because more time was needed for the
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parties to voluntarily remove exhibits and respond to the same.
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LAGOMARSINO LAW
3005 West Horizon Ridge Parkway, Suite 241, Henderson, Nevada 89052
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Thereafter, the parties
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(2) The parties’ counsel exchanged revised exhibit lists on February 19, 2020. Though the
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original batch of exhibits has been reduced, there are still tens of thousands of pages of exhibits that
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can be reduced if the parties have more time to do so. Counsel for all parties have conducted
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several lengthy telephone conferences in an effort to reduce the total amount of pages and exhibits
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to be introduced at trial. After several telephone conferences, the parties have agreed that further
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reductions are warranted. The parties’ counsel have dedicated numerous individuals to the arduous
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task of reducing and organizing the tens of thousands of documents produced in discovery to a
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more manageable number for trial.
from their respective lists, to consider stipulations, if any, and to make determinations as to
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objections for those that remain; and
Facsimile (702) 383-0065
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(4) The parties requested the extension of 79 days because counsel for the parties want to
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ensure that they have sufficient availability to review documents and information necessary for the
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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
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agreed on the following internal deadlines related to the Joint Pretrial Order:
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1) The parties are to re-disclose proposed exhibits on April 20, 2020.
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2) The parties are to serve objections to proposed exhibits on May 13, 2020.
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3) The parties will exchange language to be incorporated into the Joint Pretrial Order on
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May 21, 2020.
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4) The parties will conduct a telephone conference on May 28, 2020 to discuss final
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language to be incorporated into the Pretrial Order and any remaining issues. Should the parties not
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agree on the final language in the Pretrial Order, the parties have agreed to file individual Pretrial
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Orders.
5) The parties agree to identify potential deposition transcript designations of unavailable
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Telephone (702) 383-2864
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witnesses, parties and 30(b)(6) witnesses sixty (60) days before trial.
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LAGOMARSINO LAW
(3) The parties need more time to voluntarily organize, cull, and/or perhaps remove exhibits
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3005 West Horizon Ridge Parkway, Suite 241, Henderson, Nevada 89052
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6) The parties will file the Pretrial Order by June 4, 2020.
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This extension is made in good faith and is not intended for purposes of delay.
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IT IS SO STIPULATED AND AGREED.
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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
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Telephone (702) 383-2864
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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
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IT IS SO ORDERED.
_________________________________________
UNITED STATES MAGISTRATE JUDGE
3-5-2020
_________________________________________
DATED
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Facsimile (702) 383-0065
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LAGOMARSINO LAW
3005 West Horizon Ridge Parkway, Suite 241, Henderson, Nevada 89052
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