Wynn v. Bloom et al
Filing
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ORDER Granting #48 Stipulation re Completion of Authorized Discovery and Briefing Schedule on Renewed Anti-Slapp Motion. Discovery due by 8/9/2019. Responses due by 8/30/2019. Replies due within 14 days after service of Wynn's response. Signed by Judge James C. Mahan on 5/14/2019. (Copies have been distributed pursuant to the NEF - SLD)
Case 2:18-cv-00609-JCM-GWF Document 48 Filed 05/14/19 Page 1 of 4
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L. LIN WOOD, ESQ. (pro hac vice)
lwood@linwoodlaw.com
NICOLE JENNINGS WADE, ESQ. (pro hac vice)
nwade@linwoodlaw.com
JONATHAN D. GRUNBERG, ESQ. (pro hac vice)
jgrunberg@linwoodlaw.com
G. TAYLOR WILSON, ESQ. (pro hac vice)
twilson@linwoodlaw.com
L. LIN WOOD, P.C.
1180 West Peachtree Street, Suite 2040
Atlanta, Georgia 30309
Telephone: 404.891.1402
Facsimile: 404.506.9111
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Attorneys for Plaintiff Steve Wynn
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701 S. 7 t h Street
Las Vegas, NV 89101
702.786.1001
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PETERSON BAKER, PLLC
TAMARA BEATTY PETERSON, ESQ., Bar No. 5218
tpeterson@petersonbaker.com
NIKKI L. BAKER, ESQ., Bar No. 6562
nbaker@petersonbaker.com
PETERSON BAKER, PLLC
701 S. 7th Street
Las Vegas, NV 89101
Telephone: 702.786.1001
Facsimile: 702.786.1002
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
STEVE WYNN, an individual,
Case No.: 2:18-cv-00609-JCM-GWF
Plaintiff,
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v.
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LISA BLOOM, an individual; and THE
BLOOM FIRM, a California Professional
Corporation,
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Defendants.
STIPULATION AND [PROPOSED]
ORDER RE: COMPLETION OF
AUTHORIZED DISCOVERY AND
BRIEFING SCHEDULE ON RENEWED
ANTI-SLAPP MOTION
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Plaintiff Steve Wynn ("Mr. Wynn"), by and through his attorneys of record, Tamara Beatty
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Peterson, Esq. and Nikki L. Baker, Esq., of Peterson Baker, PLLC, and L. Lin Wood, Esq., Nicole
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Jennings Wade, Esq., Jonathan D. Grunberg, Esq., and G. Taylor Wilson, Esq., of L. Lin Wood,
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P.C., and Defendants Lisa Bloom and The Bloom Firm (collectively, the "Bloom Defendants"),
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by and through their attorneys of record, Marc J. Randazza, Esq., Ronald D. Green, Esq., and Alex
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J. Shepard, Esq., of the Randazza Legal Group, PLLC, hereby agree and stipulate, subject to the
Case 2:18-cv-00609-JCM-GWF Document 48 Filed 05/14/19 Page 2 of 4
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Court's approval, as follows:
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On March 26, 2019, Mr. Wynn filed his "Motion for Discovery to Respond to
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Defendants' Special Motion to Dismiss Pursuant to NRS 41.660" [ECF No. 34] ("Discovery
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Motion"), requesting that the Court permit Mr. Wynn to engage in certain discovery prior to
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responding to any anti-SLAPP motion filed by the Bloom Defendants, and requesting a scheduling
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order for such discovery and briefing.
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2.
On March 28, 2019, the Bloom Defendants filed "Defendants Lisa Bloom and The
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Bloom Firm's Renewed Special Motion to Dismiss Pursuant to NRS 41.660" [ECF No. 36]
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("Renewed anti-SLAPP Motion").
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3.
On April 8, 2019, the Court entered an order granting Mr. Wynn's "Motion for
Extension of Time to Respond to Defendants' Renewed Anti-SLAPP Motion [ECF No. 36]" [ECF
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701 S. 7th Street
Las Vegas, NV 89101
702.786.1001
PETERSON BAKER, PLLC
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No. 38] (the "Extension Order"). See ECF No. 39. In the Extension Order, the Court ordered,
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among other things, that "if the court grants in whole or in part plaintiff's discovery motion, plaintiff
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shall file a motion requesting a proposed deadline to file a response" to the Renewed anti-SLAPP
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Motion. Id.
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4.
On May 5, 2019, the Court entered an order granting, in part, and denying, in part,
Mr. Wynn's Discovery Motion (the "Discovery Order"). See ECF No. 45.
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In the Discovery Order, the Court ordered the parties to "submit a proposed schedule
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for completion of the authorized discovery, together with a briefing schedule on Defendants'
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Renewed Motion to Dismiss Pursuant to NRS 41.660 (ECF No. 36)." See ECF No. 45 at 11:2-4.
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6.
The Parties propose the following schedule for completion of discovery authorized
by the Discovery Order:
a.)
Mr. Wynn is not required to renew and re-serve his requests for production;
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rather, the requests, and the documents required to be produced by the Bloom Defendants, are
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limited by the Discovery Order;
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b.)
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No later than two (2) weeks after entry of an Order approving this
Stipulation, the Bloom Defendants shall respond to Mr. Wynn's "First Set of Requests for
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Case 2:18-cv-00609-JCM-GWF Document 48 Filed 05/14/19 Page 3 of 4
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Production of Documents to Defendant The Bloom Firm [Nos. 1-28]" served on January 30, 2019,
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subject to the limitations in paragraph 2 of the Discovery Order (ECF No. 45 at p. 10). To that end,
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the Bloom Defendants need not produce documents in response to Request Nos. 22, 23, and 24;
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c.)
No later than two (2) weeks after entry of an Order approving this
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Stipulation, the Bloom Defendants shall disclose all known contact information for Angelina
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Mullins, Colt Prattes, Samuel Cahn-Temes, and Lauren Molina to enable Mr. Wynn to subpoena
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these individuals for their depositions. However, any disclosure may be limited by the rules of
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professional conduct. In the event that it is, such limitation shall be explained, in writing;
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d.)
The depositions of Angelina Mullins, Colt Prattes, Samuel Cahn-Temes, and
Lauren Molina shall be taken first, followed by the deposition of Jordan Olsin, and then the
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deposition of Charles Glasser, Esq.;
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701 S. 7th Street
Las Vegas, NV 89101
702.786.1001
PETERSON BAKER, PLLC
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e.)
Provided the depositions of Angelina Mullins, Colt Prattes, Samuel Cahn-
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Temes, Lauren Molina, and Jordan Olsin have been completed and the Bloom Defendants have
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complied with Paragraph 6(b), supra, Mr. Wynn shall depose Mr. Glasser in New York City on
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July 2, 2019, and shall be responsible for paying Mr. Glasser's hourly fee of $550.00 for his actual
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deposition time;
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f.)
Each of the above depositions shall be limited to the durations set forth in
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the Discovery Order and to questions relevant to the issue of whether the Bloom Defendants acted
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with actual malice in publishing their press release of March 22, 2018;
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g.)
Mr. Wynn is not precluded from requesting leave of court to conduct a
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second deposition of Angelina Mullins, Colt Prattes, Samuel Cahn-Temes, Lauren Molina, Jordan
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Olsin, and/or Charles Glasser, Esq. on issues other than actual malice, or from exceeding the seven
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(7) hour limitation set forth in Fed. R. Civ. P. 30(d)(1) for Ms. Mullins, Mr. Oslin and/or Mr.
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Glasser, should the Court deny the Bloom Defendants' Renewed anti-SLAPP Motion; and
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h.)
Mr. Wynn has until and including August 9, 2019, to complete the discovery
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authorized by the Discovery Order. However, Mr. Wynn may seek leave of Court to extend this
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discovery period for good cause shown.
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Case 2:18-cv-00609-JCM-GWF Document 48 Filed 05/14/19 Page 4 of 4
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7.
The Parties propose the following briefing schedule for the Renewed anti-SLAPP
Motion:
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a.)
Mr. Wynn shall file and serve his response in opposition to the Renewed
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anti-SLAPP Motion on or before twenty-one (21) days following the completion of the above-
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described discovery, and in any event no later than August 30, 2019; and
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701 S. 7th Street
Las Vegas, NV 89101
702.786.1001
PETERSON BAKER, PLLC
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b.)
The Bloom Defendants shall file and serve their reply in support of the
Renewed anti-SLAPP Motion fourteen (14) days after service of Mr. Wynn's response.
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The Parties submit this Stipulation in compliance with the Extension Order and the
Discovery Order, and respectfully submit that good cause exists for the Court to approve this
Stipulation.
Respectfully submitted this 14th day of May, 2019.
PETERSON BAKER, PLLC
RANDAZZA LEGAL GROUP, PLLC
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By:_/s/ Nikki L. Baker________________
TAMARA BEATTY PETERSON ESQ.
Nevada Bar No. 5218
NIKKI L. BAKER, ESQ., Bar No. 6562
PETERSON BAKER, PLLC
701 S. 7th Street
Las Vegas, NV 89101
Telephone: 702.786.1001
Facsimile: 702.786.1002
By:_/s/ Alex J. Shepard _______________
MARC J. RANDAZZA, ESQ.
Nevada Bar No. 12265
RONALD D. GREEN, ESQ.
Nevada Bar No. 7360
ALEX J. SHEPARD, ESQ.
Nevada Bar No. 13582
2764 Lake Sahara Drive, Suite 109
Las Vegas, Nevada 89117
Telephone: 702.420.2001
Facsimile: 305.437.7662
ecf@randazza.com
Attorneys for Defendants Lisa Bloom
and The Bloom Firm
L. LIN WOOD, ESQ.
(Admitted Pro Hac Vice)
NICOLE JENNINGS WADE, ESQ.
(Admitted Pro Hac Vice)
JONATHAN D. GRUNBERG, ESQ.
(Admitted Pro Hac Vice)
G. TAYLOR WILSON, ESQ.
(Admitted Pro Hac Vice)
L. LIN WOOD, P.C
1180 West Peachtree Street, Suite 2040
Atlanta, Georgia 30309
Attorneys for Plaintiff Steve Wynn
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IT IS SO ORDERED.
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____________________________________________________
UNITED STATES MAGISTRATE/DISTRICT COURT JUDGE
UNITED STATES MAGISTRATE JUDGE
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5/14/2019
DATED: _______________________
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