Campbell v. Everything Breaks, Inc.

Filing 38

ORDER Granting 37 Motion to Appear Remotely re 33 Order. IT IS FURTHER ORDERED that counsel for Plaintiff must contact Elvia Garcia, courtroom deputy for the undersigned Magistrate Judge by 12:00 p.m. on May 10, 2024, at [e-mail], and provide their email addresses. The courtroom deputy will email Mr. Miltenberger and Mr. Morgan the Zoom link. Signed by Magistrate Judge Elayna J. Youchah on 5/9/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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Craig K. Perry
Nevada Bar No. 3786
CRAIG K. PERRY & ASSOCIATES
6210 N. Jones Blvd. #753907
Las Vegas, Nevada 89136-8985
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Chris R. Miltenberger, Esquire
The Law Office of Chris R. Miltenberger, PLLC
1360 N. White Chapel, Suite 200
Southlake, Texas 76092-4322
817-416-5060 (office)
817-416-5062 (fax)
[e-mail]
Pro Hac Vice

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Max S. Morgan, Esquire
THE WEITZ FIRM, LLC
1515 Market Street, #1100
Philadelphia, PA 19102
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Pro Hac Vice
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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STEPHAN CAMPBELL, on behalf of
Case No.: 2:23-cv-00861-GMN-EJY
himself and all others similarly situated,
MOTION TO CONVERT MAY 14,
Plaintiff,
2024 HEARING ON PLAINTIFF’S
v.
MOTION TO COMPEL
DISCOVERY RESPONSES TO
EVERYTHING BREAKS, INC.,
VIDEOCONFERENCE; PROPOSED
ORDER
Defendant.
PLAINTIFF’S MOTION TO CONVERT MAY 15, 2024 HEARING ON PLAINTIFF’S MOTION TO COMPEL TO
VIDEOCONFERENCE AND PERMITTING PLAINTIFF’S COUNSEL TO APPEAR REMOTELY
CASE NO. 2:23-CV-00861

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TO THE COURT, EACH PARTY AND THEIR ATTORNEY OF
RECORD:

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PLEASE TAKE NOTICE that pursuant to this Court’s procedures,

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Plaintiff Stephan Campbell (“Plaintiff”), by and through his attorneys of record,

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will and hereby does move this Honorable Court for an order converting the May

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14, 2024 Hearing on Plaintiff’s Motion to Compel Discovery Responses to a

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Videoconference hearing and permitting Plaintiffs’ Counsel (i.e., Craig Perry,

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Chris R. Miltenberger and Max S. Morgan) to appear remotely at the hearing set to

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occur on May 14, 2024 at 10:00 AM. ECF No. 33.

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Plaintiff’s Co-Lead Counsel Chris Miltenberger is located in Southlake,

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Texas (Dallas/Fort Worth Metroplex). Plaintiff’s Co-Lead Counsel Max Morgan

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is located in Philadelphia, PA. Mr. Miltenberger intends to argue Plaintiff’s Motion

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to Compel Discovery Responses at the May 14, 2024 hearing with the support of

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Mr. Morgan. Travel to Las Vegas for Mr. Miltenberger would involve 7 hours

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between travel to the airports, courthouse, and flight time. Costs would be over

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$700 for airfare and hotel. Travel to Las Vegas for Mr. Morgan would involve 8

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hours between travel to the airports, courthouse, and flight time. Costs would be

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over $1,000 for airfare and hotel. On May 8, 2024, the Court granted Defense

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Counsel’s request to appear remotely. The parties anticipate that a

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videoconference appearance will likely only involve about 1 hour of time. Thus, to

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appear in person at this hearing will be a substantial cost that may be reasonably

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avoided by a video/Zoom or telephonic appearance for Mr. Miltenberger and Mr.

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Morgan.

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PLAINTIFF’S MOTION TO CONVERT MAY 15, 2024 HEARING ON PLAINTIFF’S MOTION TO COMPEL
TO VIDEOCONFERENCE AND PERMITTING PLAINTIFFS’ COUNSEL TO APPEAR REMOTELY

CASE NO. 2:23-CV-00861

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On May 7, 2024, Defense Counsel and Plaintiff’s Counsel conferred and

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Defense Counsel does not oppose Plaintiff’s request for Plaintiff’s Counsel to

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appear remotely.

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Dated:

May 8, 2024.

Respectfully submitted,

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/s/ Chris R. Miltenberger
Chris R. Miltenberger, Esquire
The Law Office of Chris R.
Miltenberger, PLLC
1360 N. White Chapel, Suite 200
Southlake, Texas 76092-4322
817-416-5060 (office)
817-416-5062 (fax)
[e-mail]

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Max S. Morgan, Esquire
THE WEITZ FIRM, LLC
1515 Market Street, #1100
Philadelphia, PA 19102
Tel: [phone]
Fax: [phone]
[e-mail]
Craig K. Perry
Nevada Bar No. 3786
CRAIG K. PERRY & ASSOCIATES
6210 N. Jones Blvd. #753907
Las Vegas, Nevada 89136-8985
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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PLAINTIFF’S MOTION TO CONVERT MAY 15, 2024 HEARING ON PLAINTIFF’S MOTION TO COMPEL
TO VIDEOCONFERENCE AND PERMITTING PLAINTIFFS’ COUNSEL TO APPEAR REMOTELY

CASE NO. 2:23-CV-00861

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IT IS HEREBY ORDERED that the Motion to Convert the May 14, 2024
Hearing to Videoconference (ECF No. 37) is GRANTED.
IT IS FURTHER ORDERED that counsel for Plaintiff must contact Elvia

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Garcia, courtroom deputy for the undersigned Magistrate Judge by 12:00 p.m. on

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May 10, 2024, at [e-mail], and provide their email

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addresses. The courtroom deputy will email Mr. Miltenberger and Mr. Morgan the

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Zoom link.

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________________________________
Elayna J. Youchah
U.S. Magistrate Judge

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DATED: May 9, 2024

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PLAINTIFF’S MOTION TO CONVERT MAY 15, 2024 HEARING ON PLAINTIFF’S MOTION TO COMPEL
TO VIDEOCONFERENCE AND PERMITTING PLAINTIFFS’ COUNSEL TO APPEAR REMOTELY

CASE NO. 2:23-CV-00861