Saul Lassoff, et al. v. MGM Resorts International
ERISA Privacy ClassAction Jurisdiction
Whether the New Jersey District Court or Third Circuit Appellate Court erred in denying First to File Petitioners a Preclusion Order and preventing them from maintaining their chosen venue against an international corporation, and whether the First to File Rule is enforceable to prevent forum shopping
1. Whether the New Jersey District Court (Camden) or Third Circuit Appellate Court erred by denying FIRST TO FILE handicap Petitioners a PRECLUSION ORDER to maintain their chosen venue of Camden New Jersey against an "International" corporation with unlimited resources without Discovery ? 2. Whether the New Jersey Dis trict Court (Camden) or Third Circuit Appellate Court erred in not allowing FIRST TO FILE P etitioners the opportunity to RESPOND before (a) denying their PRECLUSION ORDER and/or (b) issuing its Opinion/Order which transferred venue across the United States from Camden New Jersey to the District of Nevada? 3. Whether the First To File Rule is available and enforceable for Petitioners to maintain their chosen venue and prevent Defendants from forum shopping and creating duplicate litigation?