Jackson v. City of Las Vegas et al

Filing 44

ORDER Granting 43 Stipulation to Vacate Hearing. The Court shall maintain continuing jurisdiction of this matter until the Stipulation and Order of Dismissal is filed. Deadline to file Stipulation and Order: 7/30/2018. Status Check set for 8/3/2018 at 11:00 AM in LV Courtroom 3D before Magistrate Judge Cam Ferenbach. Signed by Magistrate Judge Cam Ferenbach on 6/15/2018. (Copies have been distributed pursuant to the NEF - SLD)

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JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
HKM EMPLOYMENT ATTORNEYS LLP
1785 East Sahara, Suite 325
Las Vegas, Nevada 89104
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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MICHAEL D. JACKSON

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CASE NO: 2:14-CV-01794

Plaintiff,
STIPULATION AND ORDER TO
VACATE HEARING

vs.

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CITY OF LAS VEGAS; STEVE SMITH,
an individual; MAUREEN HIGGINSTEAGUE, an individual; DOE Defendants I
Through X, inclusive; and ROE
CORPORATIONS A through Z, inclusive,

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Defendants.

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COMES NOW, the Plaintiff, Michael D. Jackson hereinafter (“Jackson”) by and

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through their attorney, Jenny L. Foley, Ph.D., Esq., of the law firm of HKM Employment

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Attorneys LLP, and Defendants, CITY OF LAS VEGAS; STEVE SMITH, an individual;

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MAUREEN HIGGINS-TEAGUE, an individual; DOE Defendants Through X, inclusive; and

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ROE CORPORATIONS A through Z, inclusive (“Defendants”), by and through their attorney,
Jack O. Eslinger, Esq. of the Las Vegas City Attorney’s Office and hereby stipulate as follows:
1.

That the parties have reached an agreement to settle regarding the issues set forth

in Plaintiffs’ Complaint.

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2.

That the Settlement Conference scheduled for Tuesday, June 19, 2018 at 11:30

a.m. be vacated due to a settlement being reached.
3.

The substantive terms of the settlement are as follows:

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a. Defense counsel will provide a settlement agreement with the terms set forth
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to Plaintiff’s counsel in the next 14 days.
b. The parties aver and agree that the settlement in this matter resolves a bona
fide dispute.
c. The parties aver and agree that the settlement was reached after contested
litigation.

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The Court shall maintain continuing jurisdiction of this matter for all disputes which
arise from the settlement.
This request for the Court’s approval and judgment is made in good faith.
Dated this 14th day of June, 2018.

Dated this 14th day of June, 2018

HKM Employment Attorneys LLP

Las Vegas City Attorney’s Office

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/s/ Jenny L. Foley
Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave., Suite 325
Las Vegas, Nevada 89104

/s/ Jack O. Eslinger
Jack O. Eslinger, Esq.
Nevada Bar No. 8443
6851 West Charleston Blvd.
Las Vegas, Nevada 89117

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Page 2 of 4

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ORDER

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The Court having reviewed the foregoing proposed Stipulation, and good cause
appearing therefor: IT IS HEREBY ORDERED:

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1.

That the parties have settled all claims raised in Plaintiffs’ Complaint.

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2. That the Settlement Conference scheduled for Tuesday, June 19, 2018 at 11:30 a.m.

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is vacated due to a settlement being reached.

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3.

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The substantive terms of the settlement are as follows:
a. Defense counsel will provide a settlement agreement with the terms set forth

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to Plaintiff’s counsel in the next 14 days.

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b. The settlement in this matter resolves a bona fide dispute.

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c. The settlement was reached after contested litigation.

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///
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///
///

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until the stipulation
The Court shall maintain continuing jurisdiction of this matter for all issues related to
and order of dismissal is filed. IT IS HEREBY ORDERED that the proposed stipulation
the settlement and its enforcement.

and order for dismissal must be filed on or before July 30, 2018. IT IS FURTHER
ORDERED that a status check is scheduled for 11:00 AM, August 3, 2018, in Courtroom 3D.
June 15, 2018
Dated:

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UNITED STATES MAGISTRATE JUDGE
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Respectfully submitted by:
HKM Employment Attorneys LLP

/s/ Jenny L. Foley
Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave, Suite 325
Las Vegas, Nevada 89104
Attorney for Plaintiff

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