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)

Case 2:19-cv-00203-VCF Document 142 Filed 05/10/22 Page 1 of 3

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MARTIN J. KRAVITZ – Nevada Bar No. 83
[e-mail]
MICHAEL R. ESPOSITO – Nevada Bar No. 13482
[e-mail]
KRAVITZ, SCHNITZER & JOHNSON, CHTD.
8985 S. Eastern Avenue, Suite 200
Las Vegas, NV 89123
Telephone: [phone]
Facsimile: [phone]
PATRICIA L. GLASER
[e-mail]
SEAN RILEY
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff/Cross-Defendant
International Payment Advisors Ltd
and Marc Maxwell
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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INTERNATIONAL PAYMENT ADVISORS
LTD., a Nevada limited liability company,

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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.

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Plaintiff/Counter-Defendant International Payment Advisors LTD (“IPA”), Counter-

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Defendant Marc Maxwell (“Maxwell”), and Defendant/Counterclaimant Global Merchant Advisors,

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LLC, f/k/a Paysafe Services (US) LLC (“Paysafe/GMA”), by and through their respective counsel of

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record, stipulate and respectfully request that the Court extend the deadline for the parties to submit

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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

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30, 2022. This is the second request for an extension of this deadline and is requested because, in this

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case where there has been more than 2 million pages of documents exchanged and more than 20

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depositions taken, the Parties are in the process of spending considerable time reviewing, designating,

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and preparing all items required in the Joint Pretrial Order under the Local Rules, and meeting and

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conferring on items to be included therein. Apart from the breadth of this effort, two other matters

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support this request. First, after the initial extension request, on April 29 Paysafe/GMA filed a motion

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pursuant to Fed. R. Civ. Proc. 59 and 60 concerning the Court’s April 1 grant of partial summary

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judgment. IPA/Maxwell’s opposition to that motion is due on or before May 13, 2022. Second,

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Paysafe/GMA’s trial counsel will be travelling out of the country and unavailable during a portion of

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the requested extended period. As such, the parties believe that a shorter extension would not permit

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completion of their efforts.

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In sum, the parties have been diligent in their efforts, and will continue to be so and work

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together to create a proposed joint pre-trial order. The parties seek this extension to further that effort

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and to meet and confer concerning the information to be included in the Joint Pretrial Order, which

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the parties agree will likely be substantial. This request is made in good faith and not for purposes of

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delay.

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Dated this 5th day of May 2022.

Dated this 5th day of May 2022.

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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

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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

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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.

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UNITED STATES MAGISTRATE JUDGE
May, 2022
10th
Dated this ____ day of __________________