United States District Court, D. Nevada
AERODYNAMICS INCORPORATED, a Michigan corporation; ADI HOLDINGS COMPANY INC., a Georgia corporation, Plaintiffs,
CAESARS ENTERTAINMENT OPERATING COMPANY, INC., a Delaware corporation; STEVEN MARKHOFF, an individual; INTERNATIONAL MANAGEMENT SOLUTIONS LLC, a Delaware corporation; VIA AIRLINES, INC., a Colorado corporation; VIA AIR, LLC, a Delaware corporation; and AMOS VIZER, an individual, Defendants.
PARTIES TO SUBMIT REVISED JOINT, Corporation C. DANAHOBART,
ESQ., HEJMANOWSKI&McCREA PAUL HEJMANOWSKI, ESQ., CHARLES
MCCREA, ESQ., Attorneys for Plaintiffs, Aerodynamics
Incorporated and ADI Holdings Company, Inc.
J. Pisanelli, Esq., Debra L. Spinelli Esq., M. Magali Mercera
Esq., Emily A. Buchwald Esq., Attorneys for Caesars
Entertainment Operating Company Inc.
M. Flansburg III Esq., Troy P. Domina Esq., Attorney For
Defendant Steven Markhoff and International Management
T. Dushoff Esq., KoLESAR & LEATHAM Attorney for Defendant
Via Airlines Inc., Via Air LLC, and Amos Vizer.
STIPULATION AND ORDER TO EXTEND DEADLINE FOR PARTIES
TO SUBMIT REVISED JOINT PRETRIAL ORDER, ECF NO. 309
JENNIFER A. DORSEY JUDGE.
Aerodynamics Incorporated and ADI Holdings Company, Inc.
(collectively "Plaintiffs"), by and through their
undersigned counsel, and Defendants Caesars Entertainment
Operating Company, Inc., Steven Markhoff, International
Management Solutions, LLC, Via Airlines, Inc., Via Air, LLC,
and Amos Vizer (collectively "Defendants"), by and
through their respective undersigned counsel, hereby state as
on May 21, 2019, the parties filed the Joint Pretrial Order
("JPO") (ECF No. 307);
on May 30, 2019, the Court issued a minute order rejecting
the JPO and ordered the parties to meet and confer again to
develop a set of stipulated exhibits (exhibits that they
collectively agree may be admitted) and to file a Revised
Joint Pretrial Statement by July 12, 2019 (ECF No. 308);
between May 30, 2019, and July 12, 2019, the parties
undertook significant efforts to prepare a Master Exhibit
List which resulted in the parties agreeing to a set of
stipulated trial exhibits, withdrawing more than 500 trial
exhibits (equal to a third of the original No. of trial
exhibits), withdrawing several hundred objections, and
otherwise assembling a more manageable set of trial exhibits.
The parties engaged in several meet and confer sessions (two
by telephone and many others by email), exchanged several
detailed spreadsheets and emails addressing various of the
issues of admissibility and narrowing the No. of exhibits and
objections, and expended significant time re-evaluating each
of the originally proposed trial exhibits.
the parties believe that the Master Exhibit List can be
further refined and that the parties will be able to develop
a larger set of stipulated exhibits if allowed a brief
extension of time to further meet and confer;
the parties have scheduled a multiple-hour meet and confer
session to commence on July 16, 2019, at 9:00 am PDT for the
purpose of further agreeing upon a larger set of stipulated
no trial date is set in this action and the parties
previously requested in the JPO that trial should commence on
or after January 27, 2020 (ECF No. 307 at page 38 of 40),
such that the brief extension requested herein will not
affect the trial of this action;
the parties believe the additional meet and confer efforts
described herein and further refinement of a set of
stipulated exhibits and Master Exhibit List can be completed
in time to file the Revised Pretrial Order on or before July
ACCORDINGLY STIPULATED, by and between the undersigned
counsel for the parties, that the Revised Joint ...