Las Vegas Sun, Inc. v. Adelson ( 2020 )

1 J. RANDALL JONES, ESQ., SBN 1927 r.jones@kempjones.com 2 MICHAEL J. GAYAN, ESQ., SBN 11135 m.gayan@kempjones.com 3 MONA KAVEH, ESQ., SBN 11825 4 m.kaveh@kempjones.com KEMP JONES LLP 5 3800 Howard Hughes Parkway, 17th Floor Las Vegas, Nevada 89169 6 Telephone: (702) 385-6000 7 RICHARD L. STONE, ESQ. (pro hac vice) 8 rstone@jenner.com DAVID R. SINGER, ESQ. (pro hac vice) 9 dsinger@jenner.com 10 AMY M. GALLEGOS, ESQ. (pro hac vice) agallegos@jenner.com 11 JENNER & BLOCK LLP 633 West 5th Street, Suite 3600 12 Los Angeles, California 90071 Telephone: (213) 239-5100 13 14 Attorneys for Defendants 15 UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA 17 LAS VEGAS SUN, INC., a Nevada Case No.: 2:19-cv-01667-GMN-BNW corporation, 18 Plaintiff, STIPULATION AND ORDER TO 19 v. EXTEND DEADLINES TO FILE MOTIONS AND RELATED BRIEFING 20 SHELDON ADELSON, an individual and as the alter ego of News+Media Capital PRIOR TO THE COURT’S CASE 21 Group LLC and as the alter ego of Las MANAGEMENT CONFERENCE ON Vegas Review Journal, Inc.; PATRICK JANUARY 5, 2021 22 DUMONT, an individual; NEWS+MEDIA CAPITAL GROUP LLC, a Delaware (FIRST REQUEST) 23 limited liability company; LAS VEGAS REVIEW-JOURNAL, INC., a Delaware 24 corporation; and DOES, I-X, inclusive, 25 Defendants. 26 27 28 1 Defendants NEWS+MEDIA CAPITAL GROUP LLC, LAS VEGAS REVIEW- 2 JOURNAL, INC., SHELDON ADELSON, and PATRICK DUMONT (together collectively 3 referred to herein as “Defendants”), by and through their counsel of record, KEMP JONES, LLP, 4 and JENNER & BLOCK, LLP, and Plaintiff LAS VEGAS SUN, INC. (“Sun”), by and through 5 its counsel LEWIS ROCA ROTHGERBER CHRISTIE, LLP, PISANELLI BICE PLLC, and 6 THE ALIOTO LAW FIRM, hereby stipulate and agree as follows: 7 1. Pursuant to this Court’s June 4, 2020 Scheduling Order, the parties have “21 days 8 prior to each Case Management Conference . . . [to] file any motions deemed appropriate, with 9 oppositions due 10 days later, and replies due 4 days thereafter.” ECF No. 74 at 5:1–4. The next 10 Case Management Conference (“CMC”) is scheduled for January 5, 2021, generating a December 11 15, 2020, deadline to file motions. Due to the upcoming holidays, the deadline to file oppositions 12 and replies would be December 28, 2020, January 4, 2021, respectively. 13 2. Following a meet and confer, Counsel agree that the motion deadline, as presently 14 set, does not allow sufficient time for the parties to complete their meet-and-confer discussions 15 that may eliminate or narrow the scope of potential motions. The parties also wish to avoid an 16 expedited briefing schedule during the holiday season, particularly with oppositions due the first 17 judicial day after Christmas Day and replies due the first judicial day after New Year’s Day. 18 Further, given the narrow timespan between the reply deadline, presently set for January 4, 2021, 19 and the next CMC, set for January 5, 2021, Counsel for the parties recognize the Court may desire 20 additional time to consider the parties’ briefs prior to hearing argument on the same, particularly 21 in light of the pending motions already set to be heard that day. 22 3. Accordingly, the parties agree to modify the deadlines set forth in the Court’s 23 Scheduling Order for the parties to file appropriate pre-CMC motions as follows: 24 a. The parties shall have until December 22, 2020, to file appropriate motions; 25 b. The parties shall have until January 5, 2021, to file oppositions to any such 26 motions; and 27 c. The parties shall have until January 12, 2021, to file replies in support of 28 any such motions. ] 4. The aforementioned filing and briefing extensions are necessary to allow the 2 || parties sufficient time to engage in additional meet-and-confer discussions to attempt to narrow 3 || the issues before the Court at the time of hearing and to review and succinctly respond to any 4 || motions that may be filed. 5 5. The stipulated extensions to the filing and briefing schedule set forth in the 6 || Scheduling Order will not prejudice the parties, nor will it impact other Court-imposed deadlines 7 || established in this case. This is the first request for a continuance of these briefing deadlines. 8 || DATED this 15" day of December, 2020. DATED this _15"_ day of December, 2020. 9 || KEMP JONES, LLP LEWIS ROCA ROTHGERBER CHRISTIE LLP 10 /8/ Michael J. Gayan /8/ Marla J. Hudgens 11 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 12 Mona Kaveh, Esq., Bar No. 11825 Marla J. Hudgens, Bar No. 11098 3800 Howard Hughes Parkway, 17" Floor Nicole Scott, Bar No. 13757 13 Las Vegas, NV 89169 One East Liberty Street, Suite 300 14 Reno, NV 89501-2128 Richard L. Stone, Esq., Pro Hac Vice 15 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 16 JENNER & BLOCK LLP ALIOTO LAW FIRM 633 West 5" Street, Suite 3600 One Sansome Street, 35" Floor 17 || Los Angeles, CA 90071 San Francisco, CA 94104 18 Attorneys for Defendants James J. Pisanelli, Bar No. 4027 19 Todd L. Bice, Bar No. 4534 Jordan T. Smith, Bar No. 12097 20 PISANELLI BICE PLLC 400 South 7" Street, Suite 300 2] Las Vegas, Nevada 89101 22 Attorneys for Plaintiff 23 ORDER 24 IT IS SO ORDERED 25 DATED: 11:13 am, December 18, 2020 26 27 Gra La □□□ beta 28 BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE