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Wynn v. Bloom

United States District Court, D. Nevada

May 14, 2019

STEVE WYNN, an individual, Plaintiff,
v.
LISA BLOOM, an individual; and THE BLOOM FIRM, a California Professional Corporation, Defendants.

          TAMARA BEATTY PETERSON, ESQ., Bar No. 5218 NIKKI L. BAKER, ESQ., Bar No. 6562 PETERSON BAKER, PLLC, L. LIN WOOD, ESQ. (pro hac vice) NICOLE JENNINGS WADE, ESQ. (pro hac vice) JONATHAN D. GRUNBERG, ESQ. (pro hac vice) G. TAYLOR WILSON, ESQ. (pro hac vice) L. LIN WOOD, P.C. Attorneys for Plaintiff Steve Wynn

          MARC J. RANDAZZA, ESQ. Nevada Bar No. 12265 RONALD D. GREEN, ESQ. Nevada Bar No. 7360 ALEX J. SHEPARD, ESQ. Nevada Bar No. 13582 Attorneys for Defendants Lisa Bloom and The Bloom Firm

          STIPULATION AND [PROPOSED] ORDER RE: COMPLETION OF AUTHORIZED DISCOVERY AND BRIEFING SCHEDULE ON RENEWED ANTI-SLAPP MOTION

         Plaintiff Steve Wynn ("Mr. Wynn"), by and through his attorneys of record, Tamara Beatty Peterson, Esq. and Nikki L. Baker, Esq., of Peterson Baker, PLLC, and L. Lin Wood, Esq., Nicole Jennings Wade, Esq., Jonathan D. Grunberg, Esq., and G. Taylor Wilson, Esq., of L. Lin Wood, P.C., and Defendants Lisa Bloom and The Bloom Firm (collectively, the "Bloom Defendants"), by and through their attorneys of record, Marc J. Randazza, Esq., Ronald D. Green, Esq., and Alex J. Shepard, Esq., of the Randazza Legal Group, PLLC, hereby agree and stipulate, subject to the Court's approval, as follows:

         1. On March 26, 2019, Mr. Wynn filed his "Motion for Discovery to Respond to Defendants' Special Motion to Dismiss Pursuant to NRS 41.660" [ECF No. 34] ("Discovery Motion"), requesting that the Court permit Mr. Wynn to engage in certain discovery prior to responding to any anti-SLAPP motion filed by the Bloom Defendants, and requesting a scheduling order for such discovery and briefing.

         2. On March 28, 2019, the Bloom Defendants filed "Defendants Lisa Bloom and The Bloom Firm's Renewed Special Motion to Dismiss Pursuant to NRS 41.660" [ECF No. 36] ("Renewed anti-SLAPP Motion ")

         3. On April 8, 2019, the Court entered an order granting Mr. Wynn's "Motion for Extension of Time to Respond to Defendants' Renewed Anti-SLAPP Motion [ECF No. 36]" [ECF No. 38] (the "Extension Order"). See ECF No. 39. In the Extension Order, the Court ordered, among other things, that "if the court grants in whole or in part plaintiffs discovery motion, plaintiff shall file a motion requesting a proposed deadline to file a response" to the Renewed anti-SLAPP Motion. Id.

         4. On May 5, 2019, the Court entered an order granting, in part, and denying, in part, Mr. Wynn's Discovery Motion (the "Discovery Order"). See ECF No. 45.

         5. In the Discovery Order, the Court ordered the parties to "submit a proposed schedule for completion of the authorized discovery, together with a briefing schedule on Defendants' Renewed Motion to Dismiss Pursuant to NRS 41.660 (ECF No. 36)." See ECF No. 45 at 11:2-4.

         6. The Parties propose the following schedule for completion of discovery authorized by the Discovery Order:

a.) Mr. Wynn is not required to renew and re-serve his requests for production; rather, the requests, and the documents required to be produced by the Bloom Defendants, are limited by the Discovery Order;
b.) No. later than two (2) weeks after entry of an Order approving this Stipulation, the Bloom Defendants shall respond to Mr. Wynn's "First Set of Requests for Production of Documents to Defendant The Bloom Firm [Nos. 1-28]" served on January 30, 2019, subject to the limitations in paragraph 2 of the Discovery Order (ECF No. 45 at p. 10). To that end, the Bloom Defendants need not produce documents in response to Request Nos. 22, 23, and 24;
c.) No. later than two (2) weeks after entry of an Order approving this Stipulation, the Bloom Defendants shall disclose all known contact information for Angelina Mullins, Colt Prattes, Samuel Cahn-Temes, and Lauren Molina to enable Mr. Wynn to subpoena these individuals for their depositions. However, any disclosure may be limited by the rules of professional conduct. In the event that it is, such limitation shall be explained, in writing;
d.) The depositions of Angelina Mullins, Colt Prattes, Samuel Cahn-Temes, and Lauren Molina shall be taken first, followed by the deposition of Jordan Olsin, and then the deposition of Charles Glasser, Esq.;
e.) Provided the depositions of Angelina Mullins, Colt Prattes, Samuel Cahn-Temes, Lauren Molina, and Jordan Olsin have been completed and the Bloom Defendants have complied with Paragraph 6(b), supra, Mr. Wynn shall depose Mr. Glasser in New York City on July 2, 2019, and shall be responsible for ...

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