Estate of Barry Isom v. United States Department of the Interior et al

Filing 38

ORDER Granting 37 Stipulation for Travel Costs. Signed by Magistrate Judge Cam Ferenbach on 6/10/2015. (Copies have been distributed pursuant to the NEF - DC)

1 DANIEL G. BOGDEN
United States Attorney
2 District of Nevada
3 BLAINE T. WELSH
Nevada Bar No. 4790
4 KRYSTAL J. (GALLAGHER) ROSSE
Nevada Bar No. 11573
5 Assistant United States Attorneys
333 Las Vegas Boulevard South, Suite 5000
6 Las Vegas, Nevada 89101
Telephone: [phone]
7 Facsimile: 702-388-6787
Email: [e-mail]
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Attorneys for the United States.
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

12 THE ESTATE OF BARRY ISOM, by and
through its Executrix, Mary Love-Isom; Jaime
13 Isom Newberry and Kimberly Isom Grindstaff;
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Plaintiffs,
v.

16 UNITED STATES OF AMERICA,
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Defendant.

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) Case No. 2:14-cv-00475-RFB-VCF
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STIPULATION AND ORDER FOR TRAVEL COSTS
The parties, by and through their respective counsel of record, hereby stipulate and agree that

21 Plaintiffs’ counsel reimburse the United States for travel costs related to taking Plaintiff Kimberlee Isom
22 Grindstaff’s deposition in Sacramento, California, on June 3, 2015.
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Generally, a plaintiff must be deposed in the place where suit is filed. In this case, rather than file

24 a discovery motion attempting to enforce this general rule, the parties met, conferred and agreed that
25 counsel for the United States would travel to Plaintiff’s location for the deposition and Plaintiff would
26 pay Federal Defendant’s related travel costs.

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Under Government financial rules, to effectuate this agreement and allow Plaintiffs to reimburse

2 the United States, the parties’ agreement must be reduced to a court order.
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WHEREFORE, the parties respectfully request that the Court order Plaintiffs’ counsel to

4 reimburse Federal Defendant for $577.11 in travel costs for its travel to and from Sacramento,
5 California, to conduct Plaintiff Kimberlee Isom Grindstaff’s deposition on June 3, 2015. The parties
6 further agree that neither party will claim these costs as additional compensation or reimbursable costs
7 to be taxed by the Court.
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Respectfully submitted this 8th day of June 2015.

9 CRAIG A. MARQUIZ
Marquiz Law Office, PC
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JUSTICE LAW CENTER
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/s/ Alissa C. Engler
12 BRET O. WHIPPLE, ESQ.
ALISSA C. ENGLER, ESQ.
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Attorneys for Plaintiffs
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DANIEL G. BOGDEN
United States Attorney
/s/ Krystal J. Rosse
BLAINE T. WELSH
KRYSTAL J. (GALLAGHER) ROSSE
Assistant United States Attorneys
Attorneys for the United States

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
DATED:
June 10, 2015

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