Case Information
*1 1 J. R ANDALL J ONES , E SQ ., SBN 1927 r.jones@kempjones.com
2 M ICHAEL J. G AYAN , E SQ ., SBN 11135 m.gayan@kempjones.com M ONA K AVEH , E SQ ., SBN 11825
m.kaveh@kempjones.com
KEMP JONES LLP Telephone: (702) 385-6000
R ICHARD L. S TONE , E SQ . ( pro hac vice )
rstone@jenner.com
D AVID R. S INGER , E SQ . ( pro hac vice ) dsinger@jenner.com
A MY M. G ALLEGOS , E SQ . ( pro hac vice ) agallegos@jenner.com
JENNER & BLOCK LLP
Los Angeles, California 90071
Telephone: (213) 239-5100
Attorneys for Defendants
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
LAS VEGAS SUN, INC., a Nevada Case No.: 2:19-cv-01667-GMN-BNW
corporation, Plaintiff, STIPULATION AND ORDER TO
v. EXTEND DEADLINES TO FILE MOTIONS AND RELATED BRIEFING
SHELDON ADELSON, an individual and PRIOR TO THE COURT’S CASE as the alter ego of News+Media Capital MANAGEMENT CONFERENCE ON Group LLC and as the alter ego of Las Vegas Review Journal, Inc.; PATRICK
JANUARY 5, 2021 DUMONT, an individual; NEWS+MEDIA CAPITAL GROUP LLC, a Delaware limited liability company; LAS VEGAS REVIEW-JOURNAL, INC., a Delaware corporation; and DOES, I-X, inclusive,
(FIRST REQUEST) Defendants.
*2
Defendants NEWS+MEDIA CAPITAL GROUP LLC, LAS VEGAS REVIEW- JOURNAL, INC., SHELDON ADELSON, and PATRICK DUMONT (together collectively referred to herein as “Defendants”), by and through their counsel of record, KEMP JONES, LLP, and JENNER & BLOCK, LLP, and Plaintiff LAS VEGAS SUN, INC. (“Sun”), by and through its counsel LEWIS ROCA ROTHGERBER CHRISTIE, LLP, PISANELLI BICE PLLC, and THE ALIOTO LAW FIRM, hereby stipulate and agree as follows: Pursuant to this Court’s June 4, 2020 Scheduling Order, the parties have “21 days
prior to each Case Management Conference . . . [to] file any motions deemed appropriate, with oppositions due 10 days later, and replies due 4 days thereafter.” ECF No. 74 at 5:1–4. The next Case Management Conference (“CMC”) is scheduled for January 5, 2021, generating a December 15, 2020, deadline to file motions. Due to the upcoming holidays, the deadline to file oppositions and replies would be December 28, 2020, January 4, 2021, respectively.
2. Following a meet and confer, Counsel agree that the motion deadline, as presently set, does not allow sufficient time for the parties to complete their meet-and-confer discussions that may eliminate or narrow the scope of potential motions. The parties also wish to avoid an expedited briefing schedule during the holiday season, particularly with oppositions due the first judicial day after Christmas Day and replies due the first judicial day after New Year’s Day.
Further, given the narrow timespan between the reply deadline, presently set for January 4, 2021, and the next CMC, set for January 5, 2021, Counsel for the parties recognize the Court may desire additional time to consider the parties’ briefs prior to hearing argument on the same, particularly in light of the pending motions already set to be heard that day.
3. Accordingly, the parties agree to modify the deadlines set forth in the Court’s Scheduling Order for the parties to file appropriate pre-CMC motions as follows:
a. The parties shall have until December 22, 2020, to file appropriate motions; b. The parties shall have until January 5, 2021, to file oppositions to any such motions; and
c. The parties shall have until January 12, 2021, to file replies in support of any such motions. *3 IT IS SO ORDERED DATED: BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE
4. The aforementioned filing and briefing extensions are necessary to allow the parties sufficient time to engage in additional meet-and-confer discussions to attempt to narrow the issues before the Court at the time of hearing and to review and succinctly respond to any motions that may be filed. The stipulated extensions to the filing and briefing schedule set forth in the
Scheduling Order will not prejudice the parties, nor will it impact other Court-imposed deadlines established in this case. This is the first request for a continuance of these briefing deadlines.
DATED this 15 th day of December, 2020. DATED this 15 th day of December, 2020.
KEMP JONES, LLP LEWIS ROCA ROTHGERBER
CHRISTIE LLP /s/ Michael J. Gayan /s/ Marla J. Hudgens
J. Randall Jones, Esq., Bar No. 1927 E. Leif Reid, Bar No. 5750 Michael J. Gayan, Esq., Bar No. 11135 Kristen L. Martini, Bar No. 11272
Mona Kaveh, Esq., Bar No. 11825 Marla J. Hudgens, Bar No. 11098 th Floor Nicole Scott, Bar No. 13757
Las Vegas, NV 89169 One East Liberty Street, Suite 300 Reno, NV 89501-2128
Richard L. Stone, Esq., Pro Hac Vice
Amy M. Gallegos, Esq., Pro Hac Vice Joseph M. Alioto, Pro Hac Vice David R. Singer, Esq., Pro Hac Vice Jamie L. Miller, Pro Hac Vice
JENNER & BLOCK LLP ALIOTO LAW FIRM Street, Suite 3600 One Sansome Street, 35 th
Los Angeles, CA 90071 San Francisco, CA 94104
Attorneys for Defendants James J. Pisanelli, Bar No. 4027
Todd L. Bice, Bar No. 4534 Jordan T. Smith, Bar No. 12097 PISANELLI BICE PLLC ORDER 400 South 7
Attorneys for Plaintiff
IT IS SO ORDERED : 11:13 am, December 18, 2020 ___________________________________ UNITED STATES MAGISTRATE JUDGE DATED: ____________________________