Bock, LLC v. Steelman et al

Filing 295

ORDER granting 294 Stipulation Extending Briefing Schedule Re: 292 Motion to Amend. Responses to 292 Motion to Amend due by 1/24/2025. Replies due by 1/31/2025. Signed by Magistrate Judge Elayna J. Youchah on 1/2/2025. (Copies have been distributed pursuant to the NEF - MAM)

1 Ryan T. Gormley, Esq.
[e-mail]
2 Nevada Bar No. 13494
WEINBERG, WHEELER, HUDGINS,
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GUNN & DIAL, LLC
6385 South Rainbow Blvd., Suite 400
4 Las Vegas, Nevada 89118
Telephone: [phone]
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Local Counsel for Plaintiff,
6 Ernest Bock L.L.C.
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Pro Hac Counsel for Plaintiff,
Ernest Bock L.L.C.

UNITED STATES DISTRICT COURT

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John F. Palladino, Esq.
[e-mail]
Evan M. Labov, Esq.
[e-mail]
HANKIN PALLADINO WEINTROB
BELL & LABOV, P.C.
30 South New York Avenue
Atlantic City, NJ 08401
Telephone: [phone]

DISTRICT OF NEVADA
ERNEST BOCK, L.L.C.,
Plaintiff,
Case No.: 2:19-cv-01065-JAD-EJY

vs.

PAUL STEELMAN, individually; MARYANN
STEELMAN, individually; PAUL STEELMAN,
as trustee of the Steelman Asset Protection Trust;
MARYANN STEELMAN, as trustee of the
Steelman Asset Protection Trust; JIM MAIN, as
trustee of the Steelman Asset Protection Trust;
STEPHEN
STEELMAN;
SUZANNE
STEELMAN-TAYLOR; PAUL STEELMAN as STIPULATION EXTENDING BRIEFING
trustee of the Paul C. Steelman and Maryann T. SCHEDULE ON MOTION FOR LEAVE
Steelman Revocable Living Trust; MARYANN
TO AMEND ANSWER
STEELMAN, as trustee of the Paul C. Steelman
and Maryann T. Steelman Revocable Living Trust;
(FIRST REQUEST)
PAUL STEELMAN, as the trustee of the Paul
Steelman Gaming Asset Protection Trust;
KEEPSAKE, INC.; SMMR, LLC; SMMR, LLC,
SERIES A-Z; SSSSS, LLC; SSSSS, LLC, SERIES
B; CHRISTIANIA, LLC; CHRISTIANIA, LLC,
SERIES A-Z; COMPETITION INTERACTIVE,
LLC; PAUL STEELMAN, LTD.; STEELMAN
PARTNERS, LLP; PAUL STEELMAN DESIGN
GROUP, INC.; SAPT HOLDINGS, LLC, SERIES
B; AARON SQUIRES; and MATTHEW
MAHANEY,

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Defendants.

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30037151.2

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Plaintiff Ernest Bock, L.L.C. (“Bock”), the Steelman Parties 1, the Corporate Defendants 2,

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and Matthew Mahaney, Esq. (“Mahaney”) by and through their respective undersigned counsel,

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hereby stipulate, subject to this Court’s approval, to continue the briefing deadlines relating to the

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Steelman Parties’ Motion for Leave to Amend Answer (Doc. 292) for a period of twenty-one (21)

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days. The deadlines are currently set as follows: Response deadline of Friday, January 3, 2025,

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and a Reply deadline of Friday, January 10, 2025. The parties are requesting deadlines set as

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follows: Response Deadline of Friday, January 24, 2025, and a Reply deadline of Friday, January

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31, 2025. This is the Parties’ first request to extend these deadlines.

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The subject Motion was filed by the Steelman Parties on December 20, 2024, in order to

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comply with the existing amendment deadline (December 30, 2024) but with the intention of

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extending the briefing schedule to not overlap with the holidays. Additionally, the subject Motion

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seeks leave to assert counterclaims in this matter for the first time against Bock and non-party

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Thomas E. Bock. The Motion raises numerous complex issues interwoven with the lengthy

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procedural history of multiple litigations. Among other significant issues are whether the Court

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has personal jurisdiction over Thomas E. Bock; whether amendment would be unduly prejudicial

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where certain proposed counterclaims have been litigated in New Jersey for nearly ten years;

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whether amendment is appropriate where the proposed counterclaims arise from agreements with

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New Jersey forum selection clauses that were previously enforced by the proposed

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counterclaimants; and whether amendment is appropriate where a New Jersey court previously

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denied a similar motion to amend in that matter filed by the current proposed counterclaimants.

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The “Steelman Parties” refer to Defendants Paul Steelman, individually; Maryann Steelman,
individually; Paul Steelman, as trustee of the Steelman Asset Protection Trust (“SAPT”); Maryann
Steelman, as trustee of the SAPT; Jim Main, as trustee of the SAPT; Stephen Steelman; Suzanne
Steelman-Taylor; Paul Steelman, as trustee of the Paul C. Steelman and Maryann T. Steelman
Revocable Living Trust (“RLT”); Maryann Steelman, as trustee of the RLT; and Paul Steelman,
as trustee of the Paul Steelman Gaming Asset Protection Trust.
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The “Corporate Defendants” refer to Christiania, LLC; Christiania, LLC, Series A-Z;
Competition Interactive, LLC; Keepsake, Inc.; Paul Steelman Design Group, Inc.; Paul Steelman,
Ltd.; SAPT Holdings, LLC, Series B; SMMR, LLC; SMMR, LLC, Series A-Z; SSSSS, LLC;
SSSSS, LLC, Series, B; and Steelman Partners, LLP. Bock named SMMR, LLC, Series A-Z and
Christiania, LLC, Series A-Z as defendants and contends that they consist of fifty-two (52)
separate defendants (i.e., SMMR, LLC, Series A; SMMR, LLC, Series B; etc.). The Corporate
Defendants disagree. In the interest of brevity, those defendants have been stylized as “Series AZ.”
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30037151.2

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Based on the foregoing, the parties respectfully request that the Court grant the stipulation
and approve the deadlines outlined herein.

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DATED: January 2, 2025.

DATED: January 2, 2025.

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HANKIN PALLADINO WEINTROB
BELL & LABOV, P.C.

BROWNSTEIN HYATT FARBER
SCHRECK, LLP

BY: /s/ Evan M. Labov
JOHN F. PALLADINO, ESQ. (pro hac vice)
[e-mail]
EVAN M. LABOV, ESQ. (pro hac vice)
[e-mail]
30 South New York Avenue
Atlantic City, NJ 08401
Pro-Hac Counsel for Plaintiff

BY: /s/ Emily A. Ellis
FRANK M. FLANSBURG III, ESQ., #6974
[e-mail]
EMILY A. ELLIS, ESQ., #11956
[e-mail]
100 North City Parkway, Suite 1600
Las Vegas, NV 89106-4614
Attorneys for the Steelman Parties

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DATED: January 2, 2025.

DATED: January 2, 2025.

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GREENBERG TRAURIG, LLP

SOLOMON DWIGGINS FREER &
STEADMAN, LTD.

BY: /s/ Joel Edward Tasca
JOEL EDWARD TASCA, ESQ.
[e-mail]
10845 Griffith Peak Drive, Suite 600
Las Vegas, NV 89135
Attorney for Corporate Defendants

BY: /s/ Roberto M. Campos
JEFFREY P. LUSZECK, ESQ.
[e-mail]
ROBERTO M. CAMPOS, ESQ.
[e-mail]
9060 West Cheyenne Avenue
Las Vegas, NV 89129
Attorney for Matthew Mahaney, Esq.

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ORDER

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IT IS SO ORDERED on this 2nd day of January, 2025.

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UNITED STATES MAGISTRATE JUDGE

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30037151.2

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