teamLab Inc. v. Arte Museum LV, LLC et al

Filing 40

ORDER granting 39 Stipulation to Modify Existing Scheduling Order. Discovery due by 3/17/2025. Motions due by 4/16/2025. Proposed Joint Pretrial Order due by 5/15/2025. Signed by Magistrate Judge Daniel J. Albregts on 11/26/2024. (Copies have been distributed pursuant to the NEF - MAM)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

LEWIS ROCA ROTHGERBER
CHRISTIE LLP
Eric N. Kohli (Bar No. 15763)
[e-mail]
3993 Howard Hughes Parkway
Suite 600
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Ryan Goldstein (Pro Hac Vice)
[e-mail]
Daniel C. Posner (Pro Hac Vice)
[e-mail]
865 S. Figueroa Street, 10th Floor
Los Angeles, CA 90017
Telephone: [phone]
Michael LaFond (Pro Hac Vice)
[e-mail]
555 Twin Dolphin Drive, 5th Floor
Redwood City, CA 94065
Telephone: [phone]
Attorneys for Plaintiff

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

17
19
20
21
22
23
24

FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER LLP
Jenevieve J. Maerker (Pro Hac Vice)
[e-mail]
Danny Awdeh (Pro Hac Vice)
[e-mail]
Yoonhee Kim (Pro Hac Vice)
[e-mail]
Patrick J. Rodgers (Pro Hac Vice)
[e-mail]
Maxime I. Jarquin (Pro Hac Vice)
[e-mail]
901 New York Avenue NW
Washington, DC 20001
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants

16
18

GREENBERG TRAURIG, LLP
Mark G. Tratos (Bar No. 01086)
[e-mail]
Bethany L. Rabe (Bar No. 11691)
[e-mail]
10845 Griffith Peak Drive
Suite 600
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]

TEAMLAB INC., a Japanese
corporation,
Plaintiff,
vs.
ARTE MUSEUM LV, LLC, a Delaware
limited liability company, D’STRICT
HOLDINGS, INC., a Delaware
Corporation, and D’STRICT KOREA
INC., a Korean Corporation,

Case No. 2:23-cv-01956-JAD-DJA
STIPULATION AND ORDER TO
MODIFY EXISTING SCHEDULING
ORDER
[SECOND REQUEST]

Defendants.

25
26

Pursuant to LR IA 6-1 and 6-2, and LR 26-3, Plaintiffs and Defendants stipu-

27

late, by and through their respective counsel, to request the Court to extend their cur-

28

rent discovery deadlines by thirty (30) days.
STIPULATION AND ORDER TO MODIFY EXISTING SCHEDULING ORDER
ACTIVE 704448212v1

1

1.

2

the discovery schedule (by 60 days) due largely to the delays associated with having

3

foreign clients on both sides of the case, and the difficulties of conducting foreign

4

discovery involving foreign-language documents. The parties had also, at that time,

5

initiated informal settlement discussions.

6

2.

7

and have made substantial progress toward a negotiated resolution of their dispute.

8

3.

9

parties have exchanged responses to interrogatories and requests for production, and

10

both sides have made multiple document productions on a rolling basis. The parties

11

continue to search for and review responsive documents and expect to be able to com-

12

plete their document productions in the near future.

13

4.

14

gistics and scheduling, but they have held off on scheduling depositions and resolving

15

remaining document production issues, in order to focus their efforts on the settlement

16

negotiations. At this point, deposition rooms at the U.S. Consulate in Tokyo, where

17

some depositions may need to be conducted, are not available until January 6, 2025

18

or later (see https://jp.usembassy.gov/services/depositions-in-japan/).

19

5.

20

will be necessary to complete written discovery and depositions before serving their

21

respective expert disclosures.

22

6.

23

lines will facilitate their completion of settlement discussions and, as needed, discov-

24

ery.

25

7.

26

ties seek the extension to ensure that settlement discussions can proceed and discovery

27

can be completed if it proves necessary.

On September 23, 2024, the Court granted the parties’ first stipulation to extend

Since then, the parties have been engaged in extensive settlement discussions
In parallel, the parties have conducted further discovery activities. To date, the

No depositions have been taken yet. The parties have discussed deposition lo-

Despite the parties’ diligent efforts and progress, they agree that additional time

The parties believe that a 30-day extension of the discovery and disclosure dead-

The extension is not sought for any improper purpose or delay. Rather, the par-

28
2
STIPULATION AND ORDER TO MODIFY EXISTING SCHEDULING ORDER
ACTIVE 704448212v1

1
2

In accordance with the parties’ stipulated 30-day extension, the current discovery deadlines and the parties’ proposed extended deadlines are:

3
4
5
6
7
8
9

Scheduled Event
Expert Disclosure pursuant
to Fed. R. Civ. P. 26(a)(2)
Rebuttal Expert Disclosure
pursuant to Fed. R. Civ. P.
26(a)(2)
Discovery Cut-off
Dispositive Motions
Joint Pretrial Order

Current Deadline
December 16, 2024

Proposed Deadline
January 15, 2025

January 17, 2025

February 18, 2025

February 14, 2025
March 17, 2025
April 15, 2025

March 17, 2025
April 16, 2025
May 15, 2025

10
11

This is the parties’ second stipulated request for an extension of discovery. The

12

parties respectfully submit that their reasons set forth above constitute compelling rea-

13

sons for the requested extension.

14
15

WHEREFORE, the parties respectfully request that this Court extend the current discovery deadlines by thirty (30) days in accordance with the table above.

16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION AND ORDER TO MODIFY EXISTING SCHEDULING ORDER
ACTIVE 704448212v1

1
2

DATED this 25th of
November, 2024

3

Eric N. Kohli (Bar No. 15763)
LEWIS ROCA ROTHGERBER
CHRISTIE LLP
Ryan Goldstein (Pro Hac Vice)
Daniel C. Posner (Pro Hac Vice)
Michael LaFond (Pro Hac Vice)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP

4
5
6

By: /s/ Eric N. Kohli
Attorneys for Plaintiff

7
8
9
10

DATED this 25th of
November, 2024

11

Mark G. Tratos (Bar No. 01086)
Bethany L. Rabe (Bar No. 11691)
GREENBERG TRAURIG, LLP
Jenevieve J. Maerker (Pro Hac Vice)
Danny Awdeh (Pro Hac Vice)
Yoonhee Kim (Pro Hac Vice)
Patrick J. Rodgers (Pro Hac Vice)
Maxime I. Jarquin (Pro Hac Vice)
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER LLP

12
13
14

By: /s/ Bethany L. Rabe_________________
Attorneys for Defendants

15
16
17
18
19

ORDER

20

IT IS SO ORDERED:

21

DANIEL J. ALBREGTS
United States
District
Court/Magistrate
UNITED
STATES
MAGISTRATE
JUDGE Judge

22

Dated: _________________________

23

DATED: 11/26/2024

24
25
26
27
28

4
STIPULATION AND ORDER TO MODIFY EXISTING SCHEDULING ORDER
ACTIVE 704448212v1