International Payment Advisors, Ltd. v. Paysafe Services US, LLC

Filing 142

ORDER granting 141 Stipulation; Proposed Joint Pretrial Order due by 6/30/2022. Signed by Magistrate Judge Cam Ferenbach on 5/10/2022. (Copies have been distributed pursuant to the NEF - HAM)

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Case 2:19-cv-00203-VCF Document 142 Filed 05/10/22 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 MARTIN J. KRAVITZ – Nevada Bar No. 83 mkravitz@ksjattorneys.com MICHAEL R. ESPOSITO – Nevada Bar No. 13482 mesposito@ksjattorneys.com KRAVITZ, SCHNITZER & JOHNSON, CHTD. 8985 S. Eastern Avenue, Suite 200 Las Vegas, NV 89123 Telephone: (702) 362-6666 Facsimile: (702) 362-2203 PATRICIA L. GLASER pglaser@glaserweil.com SEAN RILEY sriley@glaserweil.com GLASER WEIL FINK HOWARD AVCHEN & SHAPIRO LLP 10250 Constellation Boulevard, 19th Floor Los Angeles, California 90067 Telephone: (310) 553-3000 Facsimile: (310) 556-2920 Attorneys for Plaintiff/Cross-Defendant International Payment Advisors Ltd and Marc Maxwell UNITED STATES DISTRICT COURT 14 DISTRICT OF NEVADA 15 16 INTERNATIONAL PAYMENT ADVISORS LTD., a Nevada limited liability company, 17 18 19 20 21 22 23 Plaintiff, v. PAYSAFE SERVICES (US) LLC, a Delaware Corporation; and DOES 1-10 inclusive, Case No.: 2:19-cv-203-VCF STIPULATION AND PROPOSED ORDER TO EXTEND DEADLINE TO FILE JOINT PRETRIAL ORDER Second Request Defendants. AND ALL RELATED CLAIMS. 24 Plaintiff/Counter-Defendant International Payment Advisors LTD (“IPA”), Counter- 25 Defendant Marc Maxwell (“Maxwell”), and Defendant/Counterclaimant Global Merchant Advisors, 26 LLC, f/k/a Paysafe Services (US) LLC (“Paysafe/GMA”), by and through their respective counsel of 27 record, stipulate and respectfully request that the Court extend the deadline for the parties to submit 28 the Joint Pretrial Order by twenty- eight (28) days, extending the deadline from June 2, 2022 to June Case 2:19-cv-00203-VCF Document 142 Filed 05/10/22 Page 2 of 3 1 30, 2022. This is the second request for an extension of this deadline and is requested because, in this 2 case where there has been more than 2 million pages of documents exchanged and more than 20 3 depositions taken, the Parties are in the process of spending considerable time reviewing, designating, 4 and preparing all items required in the Joint Pretrial Order under the Local Rules, and meeting and 5 conferring on items to be included therein. Apart from the breadth of this effort, two other matters 6 support this request. First, after the initial extension request, on April 29 Paysafe/GMA filed a motion 7 pursuant to Fed. R. Civ. Proc. 59 and 60 concerning the Court’s April 1 grant of partial summary 8 judgment. IPA/Maxwell’s opposition to that motion is due on or before May 13, 2022. Second, 9 Paysafe/GMA’s trial counsel will be travelling out of the country and unavailable during a portion of 10 the requested extended period. As such, the parties believe that a shorter extension would not permit 11 completion of their efforts. 12 In sum, the parties have been diligent in their efforts, and will continue to be so and work 13 together to create a proposed joint pre-trial order. The parties seek this extension to further that effort 14 and to meet and confer concerning the information to be included in the Joint Pretrial Order, which 15 the parties agree will likely be substantial. This request is made in good faith and not for purposes of 16 delay. 17 Dated this 5th day of May 2022. Dated this 5th day of May 2022. 18 KRAVITZ, SCHNITZER & JOHNSON, CHTD. GREENBERG TRAURIG, LLP /S/ Martin Kravitz MARTIN J. KRAVITZ, ESQ. Nevada Bar No. 83 8985 S. Eastern Avenue, Suite 200 Las Vegas, Nevada 89123 /s/ Jason Hicks MARK D. KEMPLE, ESQ. Admitted Pro Hac Vice JASON K. HICKS, ESQ. Nevada Bar No. 13149 10845 Griffith Peak Drive, Suite 600 Las Vegas, Nevada 89135 19 20 21 22 23 24 25 26 27 28 GLASER WEIL FINK HOWARD AVCHEN & SHAPIRO LLP PATRICIA L. GLASER, ESQ.* SEAN RILEY, ESQ.* STEVEN BASILEO, ESQ.* *Admitted Pro Hac Vice 10250 Constellation Boulevard, 19th Floor Los Angeles, California 90404 Attorneys for International Payment Advisors LTD and Marc Maxwell Attorneys for Global Merchant Advisors, LLC, f/k/a Paysafe Services (US) LLC Case 2:19-cv-00203-VCF Document 142 Filed 05/10/22 Page 3 of 3 1 2 3 4 ORDER Based upon the stipulation of the parties, and with good cause appearing, IT IS HEREBY ORDERED that the parties shall submit the Joint Pretrial Order on or before June 30, 2022. IT IS SO ORDERED. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES MAGISTRATE JUDGE May, 2022 10th Dated this ____ day of __________________

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