R. Gary Schreiber, etal VS Robert Knievel, etal

Filing 236

ORDER Granting 235 Defendants' Motion for Release of Film and Tape. Signed by Judge Lloyd D. George on 11/27/2013. (Copies have been distributed pursuant to the NEF - AC)

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Mark Borghese, Esq.
Nevada Bar No. 6231
[e-mail]
BORGHESE LEGAL, LTD.
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Tel. [phone]
Fax [phone]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RAYMOND G. SCHREIBER REVOCABLE
TRUST and ROBERT SCHREIBER, an
individual residing in Ohio,
Plaintiffs,
vs.

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THE ESTATE OF ROBERT C. KNIEVEL a/k/a
EVEL KNIEVEL; KELLY KNIEVEL, an
individual residing in Nevada; K AND K
PROMOTIONS, INC., a Nevada Corporation;
and CONANT INVESTMENT COMPANY,
LLC, a Nevada Limited Liability Company,

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Defendants.

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Defendants, THE ESTATE OF ROBERT

) Case No.: 2:05-cv-0574-LDG-PAL
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)
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) MOTION FOR RELEASE OF FILM
) AND TAPE
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C. KNIEVEL a/k/a EVEL KNIEVEL,

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KELLY KNIEVEL, K AND K PROMOT

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COMPANY, LLC (together “Defe ndants”), by and through their attorneys, Borghese Legal,

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Ltd., hereby m ove that the Film and Tape curr ently being held at th e Iron Mountain Storage

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Facility be released to K and K Promotions, Inc. (“K&K”).

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IONS, INC., and CONANT

INVESTMENT

MEMORANDUM OF POINTS AND AUTHORITIES

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On or about Septem ber 17, 2009, this Court or dered that (i) approxim ately 118 reels of

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film contained within approximately 102 reel cani sters and (ii) th ree Betacam tapes (“Film and

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Tape”) be placed at the following location : Iron Mountain, 2942 Brooks Park Drive, North Las

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Vegas, 89030 (“Storage Facility”) (See Docket #209).

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The Court further ordered that none of the Film and Tape be rem oved from the Storage

BORGHESE LEGAL, LTD.
10161 PARK RUN DRIVE,
SUITE 150
LAS VEGAS,
NEVADA 89145
[phone]

2013-11-07-Motion for Release of Film.doc

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Facility without an order from this Court or stipulation by the parties.
On November 1, 2013 this Court entered a final judgment in this case (“Judgment”) (See

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Docket #233). One of the rulings in the Judgmen t is that K&K be granted equal access to the

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Film and Tape (See Judgment at 1(d)).

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It is reques ted that th is Court ente r an order allowing K and K Promotions, Inc. to

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remove the Film and Tape f rom the Storage Fa cility. This will avoid additional fees and costs

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incurred from the Stora ge Facility charges and fulfill the e qual access granted to K&K in the

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Judgment. It is anticipated that after K&K has temporary possession of the Film and Tape the

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parties will be able to work out a reasonable system of equal access to the Film and Tape.

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DATED this 7th day of November, 2013.
Respectf

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ully Submitted,
BORGHESE LEGAL, LTD.

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Mark
10161
Las

Borghese, Esq.
Park Run Drive, Suite 150
Vegas, Nevada 89145
Attorneys for Defendants

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ORDER

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SO ORDERED.
DATED this 27th day of November, 2013.

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_______________________________________
Lloyd D. George
Sr. U.S.District Judge

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BORGHESE LEGAL, LTD.
10161 PARK RUN DRIVE,
SUITE 150
LAS VEGAS,
NEVADA 89145
[phone]

2013-11-07-Motion for Release of Film.doc

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