LT Game (Canada) Limited et al v. Scientific Games Corporation

Filing 8

ORDER Granting 7 Motion to Extend Time (First Request) to File Pro Hac Vice Application. Verified Petition for Attorney Dariush Keyhani due by 7/24/2017. Signed by Magistrate Judge Carl W. Hoffman on 5/26/2017. (Copies have been distributed pursuant to the NEF - SLD) Modified to correct deadline date on 5/26/2017 (SLD).

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AMANDA C. YEN, ESQ. (NSBN 9726)
KRISTEN T. GALLAGHER (NSBN 9561)
McDONALD CARANO LLP
2300 West Sahara Avenue, Suite 1200
Las Vegas, Nevada 89102
Telephone: [phone]
[e-mail]
[e-mail]
DARIUSH KEYHANI (pro hac vice to be submitted)
MEREDITH & KEYHANI, PLLC
125 Park Avenue, 25th Floor
New York, New York 10017
[e-mail]
Attorneys for Plaintiffs LT Game (Canada) Limited
and LT Game Limited

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LT GAME (CANADA) LIMITED and
LT GAME LIMITED,
Plaintiffs,
vs.

MOTION TO EXTEND TIME TO FILE
PRO HAC VICE APPLICATION OF
NON-RESIDENT ATTORNEY DARIUSH
KEYHANI

SCIENTIFIC GAMES CORPORATION,
(First Request)

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Case No.: 2:17-cv-01015 JAD-CWH

Defendant.

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Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, Local Rule IA 6-1 and 11-

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2, plaintiffs LT Game (Canada) Limited (“LT Game Canada”) and LT Game Limited (“LT Game”)

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(collectively, “Plaintiff”) hereby requests an order granting additional time for non-resident

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attorney Dariush Keyhani, Esq. to file his Designation of Local Counsel and Verified Petition

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(“Verified Petition”) in the above-captioned matter and asks the Court for an additional 60 days

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within which to file the application.

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This Motion is based upon the below Memorandum of Points and Authorities, the

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pleadings and papers on file herein and any arguments of counsel that may be considered at the

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hearing on this Motion by the Court.

MEMORANDUM OF POINTS AND AUTHORITIES

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I.

FACTS

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On April 7, 2017, Plaintiff, through its Nevada counsel, filed a Complaint in this matter.

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[ECF No. 1]. Plaintiff included on the caption Mr. Keyhani’s name as well, both out of respect to

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Mr. Keyhani and in anticipation of his likely eventual appearance in the matter. While Mr.

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Keyhani has never actually appeared, the inclusion of his name on the Complaint triggered the

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court’s 45-day deadline to submit a designation of local counsel. [ECF No. 4]. Pursuant to the

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Notice to Counsel Pursuant to Local Rule IA 11-2, Mr. Keyhani’s Verified Petition is due on May

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25, 2017. Id.

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Plaintiff now moves for a 60-day extension of the time to file Mr. Keyhani’s Verified

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Petition, and, respectfully, Plaintiff seeks this extension for good cause. Specifically, Plaintiff

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seeks this extension because Plaintiff and defendant Scientific Games Corporation (“Scientific

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Games”) are engaging in settlement discussions and it appears that a settlement of their dispute is

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imminent, rendering Mr. Keyhani’s appearance in this matter unnecessary. Accordingly, Plaintiff

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respectfully requests this court extend the deadline to submit the Verified Petition by 60 days, up

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to and including July 24, 2017.

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II.

LEGAL ARGUMENT

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An attorney seeking admission pro hac vice must associate with local counsel and apply

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for admission “within 45 days of his or her first appearance.” See LR IA 11-2(e). A party seeking

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to extend the time with which to comply with the requirements of LR IA 11-2 must file a motion

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“stat[ing] the reasons for the extension requested and…inform[ing] the court of all previous

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extensions of” time to comply with LR IA 11-2 the court has granted. See LR IA 6-1. Here, there

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are two reasons for the Court to grant this extension.

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First, Mr. Keyhani has never appeared in this matter. While Plaintiff’s Nevada counsel

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included Mr. Keyhani’s name on the Complaint out of respect, Mr. Keyhani has not signed or

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filed anything in this matter, nor has he entered an appearance in court. In addition, Plaintiff and

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Scientific Games are presently engaged in settlement discussions of their dispute and believe that

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settlement is highly likely in the immediate future. If Plaintiff is successful in settling this matter
Page 2 of 4

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without further litigation, Mr. Keyhani’s Verified Petition will be unnecessary. Thus, Plaintiff

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seeks this extension in order to save resources and the court clerk’s time.

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Accordingly, Plaintiff therefore requests this court extend the deadline for Plaintiff and

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Mr. Keyhani to comply with the requirements of LR IA 11-2 for 60 days [from May 25, 2017 to

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July 24, 2017] to allow Plaintiff the time to negotiate a settlement of this matter and determine

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whether such admission will be necessary.

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III.

CONCLUSION
For the foregoing reasons, Plaintiff respectfully requests a 60-day extension of time for

non-resident attorney Dariush Keyhani to submit his Verified Petition.
DATED this 25th day of May, 2017.

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McDONALD CARANO LLP

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By: /s/ Amanda C. Yen
Amanda C. Yen, Esq. (NSBN 9726)
Kristen T. Gallagher, Esq. (NSBN 9561)
2300 West Sahara Avenue, Suite 1200
Las Vegas, Nevada 89102
Telephone: [phone]
[e-mail]
[e-mail]

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Dariush Keyhani (pro hac vice to be submitted)
MEREDITH & KEYHANI, PLLC
125 Park Avenue, 25th Floor
New York, New York 10017
Telephone: [phone]
[e-mail]

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Attorneys for Plaintiffs LT Game (Canada) Limited and
LT Game Limited

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May 26, 2017

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that I am an employee of McDonald Carano LLP, and that on the

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25th day of May, 2017, a true and correct copy of the foregoing MOTION TO EXTEND TIME

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TO FILE PRO HAC VICE APPLICATION OF NON-RESIDENT ATTORNEY DARIUSH

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KEYHANI was electronically filed with the Clerk of the Court by using CM/ECF service which

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will provide copies to all counsel of record registered to receive CM/ECF notification.

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/s/ Jelena Jovanovic
An employee of McDonald Carano LLP

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