Here are the minutes from the 8th and 18th show where it says everything that you two keep claiming 04/08/2014 8:30 AM
- DEFENDANTS' MOTION FOR SUMMARY JUDGMENT [REDACTED PURSUANT TO PROTECTIVE ORDER... ...PLAINTIFFS' MOTION TO VOLUNTARILY DISMISS DEFENDANT DIGITAL FOCUS MEDIA, INC., WITHOUT PREJUDICE, PURSUANT TO NRCP 41(A)(2), AND MAKE CONFORMING AMENDMENTS TO THEIR COMPLAINT PURSUANT TO NRCP 15(A)... ...HEARING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT [REDACTED PURSUANT TO PROTECTIVE ORDER]: COURT ORDERED, timeline prepared by Deft MARKED as Court's Exhibit 1 and LODGED with the Vault. (See worksheet.) Following argument by Mr. Krieger, COURT ORDERED, motion DENIED; there are genuine issues of material fact as to the date of discovery for purposes of the statute of limitations; while the Court agrees with Judge Ellsworth there is a problem with the statute of limitations it is better served to submit special interrogatories to the jury. PLAINTIFFS' MOTION TO VOLUNTARILY DISMISS DEFENDANT DIGITAL FOCUS MEDIA, INC., WITHOUT PREJUDICE, PURSUANT TO NRCP 41(A)(2), AND MAKE CONFORMING AMENDMENTS TO THEIR COMPLAINT PURSUANT TO NRCP 15(A): Argument by Mr. Stover requesting DMI be dismissed as it is a dissolved California entity and that case proceed on Dimension and other principals. Court noted upon party's dismissal Plaintiffs cannot have them return as late as at the time of trial. After conferring with co-counsel, Mr. Stover advised they will WITHDRAW their motion to dismiss and re-file if they feel the need to do so. Court noted answers have not been filed and DIRECTED counsel to do so in two (2) weeks. Mr. Krieger stated this will be done. Regarding 16.1 disclosures, Mr. Krieger advised a kind of initial exchange has been done but it will be worthwhile to do this again. COURT ORDERED, matter SET for Rule 16.1 Conference on April 18, 2014. Client representatives may but are not required to appear. Mr. Krieger inquired whether there will be a bifurcation with regards to sending special interrogatories to the jury. Court stated the same jury will be used. 4-18-14 8:30 AM MANDATORY RULE 16 CONFERENCE..
04/18/2014 8:30 AM
- Court made its disclosure regarding contact with Mr. Lee. Parties had no objection. Mr. Stover advised he gave a copy of the 2nd Amended Complaint to Defts last night; some allegations were added to make the complaint consistent with discovery and change the counts. Court DIRECTED counsel to do a motion and it will be heard an OST. Mr. Krieger advised when Defts filed a motion to dismiss in June with Department V one of the issues raised was an unnecessary dispensable party, which seems to have been overshadowed by the statute of limitations issue; Defts request briefing on this issue, as well as briefing with regard to the trade secret; they believe there should be a more definite statement regarding this in the amended complaint. Court stated if it is a trade secret this is usually be done separately under seal. Upon inquiry of the Court, Mr. Krieger advised parties did make their initial disclosures but only those related to the statute of limitations; they have also come to an agreement regarding ESI, i.e. to produce only in .tif or .pdf format, and regarding electronic service. COURT ORDERED, Electronic Filing and Service Order (EFSO) ENTERED. Mr. Krieger confirmed parties have a protective order in place. COURT ORDERED, requirement of filing a Joint Case Conference Report WAIVED. Both sides stated they will need one month for their standard Rule 16.1 disclosures. Court noted during that time period trade secret and dispensable party issue will be addressed; further, it does not think answer and counterclaim to the first amended complaint need to be filed at this time. Upon inquiry of the Court, Mr. Krieger stated there may be forensic computer experts. Colloquy regarding expert to review the code. Court noted a court-appointed expert on the trade secret would be a cleaner way to address that area. Mr. Stover advised they anticipate 15 months for both fact and expert discovery with the latter part being expert; parties would like to disclose at the same time. COURT ORDERED, experts where party bears the burden of proof DUE 4/17/15; rebuttal experts DUE 5/29/15; discovery cut-off 7/3/15; motions DUE 7/17/15. Matter SET for trial on the stack beginning September 2015. Pursuant to parties' agreement, matter REFERRED to Judge Denton (Department XIII) for Settlement Conference on 6/13/14. Mr. Lee will contact Judge Denton's Assistant for instructions and circulate same to opposing counsel. Discovery will be heard by this Court. Mr. Stover advised they would like a jury trial. Court DIRECTED counsel to file Jury Demand within five (5) business days or matter will be set for non-jury trial. 6/13/14 9:30 AM SETTLEMENT CONFERENCE (DEPT XIII) Show me where are the points that both of you say happened. They don't exist only lies to make it sound truthful, these are the transcripts WORD FOR WORD no other language was used on the 8th or 18th......
TMMI TRUDEF STILL MOVES ONWARD AND UPWARD WORLDWIDE!!.
And if we are ALL being honest;I hope they don't settle on the 13th and this does go to trial. The defendants will be BLOWN out of the water for the last and final time. Larry Panik for President 2016 maybe I'll start my own Grass Roots Movement;LLOLs!!..
