Lee et al v. University Medical Center of Southern Nevada

Filing 100

ORDER Granting 99 Stipulation to Stay Discovery Pending Settlement Negotiations. Signed by Magistrate Judge Carl W. Hoffman on 3/28/17. (Copies have been distributed pursuant to the NEF - ADR)

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LAW OFFICES OF STEVEN J. PARSONS
ANDREW L. REMPFER, ESQ.
Nevada Bar No.: 8628
[e-mail]
10091 Park Run Dr., Ste. #200
Las Vegas, NV 89145-8868
T: [phone]
F: [phone]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MEDERICK
LEE,
LESLEE
BYRNE, Case No.: 2:14-CV-00328-JCM-CWH
FRANCISCO ORNELAS-CARRANZA, and
JOJIE CLOW,
STIPULATION AND ORDER TO STAY
Plaintiffs,
DISCOVERY PENDING SETTLEMENT
NEGOTIATIONS
v.
UNIVERSITY
MEDICAL
SOUTHERN NEVADA,

CENTER

OF

Defendant.

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Plaintiffs, MEDERICK LEE, LESLEE BYRNE, FRANCISCO ORNELAS-CARRANZA, and

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JOJIE CLOW (“Plaintiffs”), and Defendant UNIVERSITY MEDICAL CENTER OF SOUTHERN

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NEVADA (“Defendant”)(collectively with Plaintiffs, the “Parties”), by and through their

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respective counsel of record, hereby stipulate as follows:

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WHEREAS:

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1.

This action was commenced against defendant University Medical Center of

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Southern Nevada (“UMC” or “Defendant”) on March 3, 2014, alleging claims pursuant to the

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Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. Dkt. No. 1. After Plaintiffs filed their first

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amended complaint on January 23, 2015, Defendant filed its answer denying Plaintiffs’
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Law Offices of Steven J. Parsons
10091 Park Run Dr., Ste. #200
Las Vegas, NV 89145-8868
[phone]; fax [phone]
[e-mail]

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factual claims, and denying Plaintiffs’ allegations regarding willfulness and liquidated

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damages on February 23, 2015.

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2.

During the next 12 months, the Parties exchanged written discovery,

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attended and defended multiple depositions of key witnesses, and searched for and

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produced a limited number of documents in responses to discovery requests.

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3.

The Parties have since engaged in multiple meet and confers independently

and pursuant to court orders, and have mutually decided to try to resolve this dispute.
4.

The Parties are currently engaging in settlement negotiations and believe that

a compromise can be reached;
5.

The Parties jointly desire to avoid further expenditure of the Court’s resources

or their own resources on this litigation pending the outcome of the settlement negotiations;
6.

To permit the opportunity to settle this action without further unnecessary

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litigation, the parties agree to (a) a four-week stay of discovery from March 24, 2017 to April

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24, 2017; and, (b) on May 1, 2017, submit a joint statement to the Court with the Parties’

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positions as to the progress of the negotiations.

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NOW, THEREFORE, IN CONSIDERATION OF THE FOREGOING, IT IS HEREBY
STIPULATED:
1.

All proceedings in this action are hereby stayed for four weeks, through and

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including April 24, 2017, pending the settlement negotiations currently being conducted by

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the parties; and,

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2.

On May 1, 2017, if the Parties have not yet concluded their settlement, they

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shall submit a status report and either a joint motion for a brief extension of the stay or a

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proposed schedule.

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Law Offices of Steven J. Parsons
10091 Park Run Dr., Ste. #200
Las Vegas, NV 89145-8868
[phone]; fax [phone]
[e-mail]

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DATED: Monday, March 27, 2017

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LAW OFFICES OF ANTHONY P. SGRO
PATTI, SGRO & ROGER
By:/s/ Alicia S. Exley, Esq.
Alicia S. Exley, Esq.
720 S. 7th Street, 3rd Floor
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

LAW OFFICES OF STEVEN J. PARSONS
By:/s/ Andrew L. Rempfer, Esq.
Andrew L. Rempfer, Esq.
10091 Park Run Dr., Ste. 200
Las Vegas, NV 89145-8868
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Law Offices of Steven J. Parsons
10091 Park Run Dr., Ste. #200
Las Vegas, NV 89145-8868
[phone]; fax [phone]
[e-mail]

ORDER

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It is so ordered.
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Dated: March _______, 2017

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UNITED STATES MAGISTRATE JUDGE

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Law Offices of Steven J. Parsons
10091 Park Run Dr., Ste. #200
Las Vegas, NV 89145-8868
[phone]; fax [phone]
[e-mail]