Rama Sou, et al. vs Michael Bash, et al.

Filing 101

ORDER Granting 100 Stipulation for Pretrial Conferenc. ( Pretrial Conference set for 12/12/2016 01:00 PM in LV Courtroom 3D before Magistrate Judge Cam Ferenbach.) Signed by Magistrate Judge Cam Ferenbach on 12/9/16. (Copies have been distributed pursuant to the NEF - ADR)

EDWARD W. SUH (Admitted pro hac vice)
LAW OFFICES OF MICHAEL K. SUH & ASSOCIATES
3810 WILSHIRE BOULEVARD, SUITE 1212
LOS ANGELES, CA 90010
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Plaintiffs
Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
KNEPPER & CLARK LLC
10040 W. Cheyenne Ave., Suite 170-109
Las Vegas, NV 89129
Phone: [phone]
FAX: [phone]
Email: [e-mail]
Email: [e-mail]
Local Counsel for Plaintiffs
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

RAMA SOU; TAI BUI; and SCOTT
ZIMMERMAN,
Plaintiffs,
v.

Case No. 2:15-cv-00698-APG-VCF
STIPULATED
REQUEST
PRETRIAL CONFERENCE

FOR

(FIRST REQUEST)

MICHAEL BASH; JEREMY BASH;
BERKLEY ENTERPRISES, INC.;
PEPPERDINE ENTERPRISES, INC.;
NINETY-FIVE FORT APACHE
COMPLEX, LLC; ROYAL VIEW,
LLC; and DOES 1 through 20,
inclusive,
Defendants

STIPULATED REQUEST FOR PRETRIAL CONFERENCE
Plaintiffs Rama Sou, Tai Bui, and Scott Zimmerman (collectively, “Plaintiffs”), on the
one hand, and defendants Michael Bash, Jeremy Bash, Berkley Enterprises, Inc., Pepperdine

Enterprises, Inc., Ninety-Five Fort Apache Complex, LLC, and Royal View, LLC (collectively,
“Defendants”), on the other hand, by and through their respective counsel, hereby stipulate as
follows:
Pursuant to D. Nev. LR 6-1 and 16-2, as well as the Court’s Minute Order of November 9,
2016 [ECF Dkt. 98] and counsel for Defendants’ appearance on December 3, 2016, the parties
request a pretrial conference regarding outstanding discovery and the depositions as stated on the
record during the November 9, 2016 hearing on Defendants’ Motion to Withdraw as Attorney
[ECF Dkt. 92].
The parties further request that the conference take place after 10:00 a.m. on Monday,
December 12, 2016, or at another time thereafter which may be convenient for the court. The
parties’ request for a Monday hearing on the pretrial conference is premised on the fact that Mr.
Edward Suh, counsel for Plaintiffs, has already made plans to travel from California to Las Vegas
for the depositions of Jeremy Bash, Michael Bash, Berkley Enterprises, Inc., and Ninety-Five
Fort Apache Complex, LLC. These depositions were noticed for December 12, 13, and 14,
respectively.1 Notice of these depositions preceded appearance of new counsel for defendants in
this case on December 3, 2016.2
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1

Specifically, on November 21, 2016, Plaintiffs noticed the deposition of Jeremy Bash was noticed for
December 12, 2016, and Michael Bash for December 13, 2016. Copies of these depositions were mailed to
defendants at their appropriate contact addresses. On November 30, 2016, having not received notification that the
individual defendants had retained new counsel, Plaintiffs noticed the depositions of Ninety-Five Fort Apache
Complex, LLC (December 14, 2016, at 9:00 a.m.), and Berkley Enterprises, Inc. (December 14, 2016, at 1:00 p.m.).
On November 30, 2016, Plaintiffs also noticed the depositions of Royal View, LLC (December 19, 2016 at 9:00
a.m.), and Pepperdine Enterprises, Inc. (December 19, 2016, at 1:00 p.m.). Copies of all 30(b)(6) deposition notices
were mailed to the addresses listed on the Nevada Secretary of State website.
2
On December 3, 2016, new counsel for defendants noticed his appearance. ECF Dkt. 99. Later that day,
counsel for plaintiffs provided courtesy copies of all six deposition notices to defendants’ counsel.

IT IS SO STIPULATED.
KNEPPER & CLARK LLC

LAW OFFICE OF ANDREW H.
PASTWICK

/s/ Miles N. Clark
MATTHEW I. KNEPPER
Nevada Bar No. 12796
MILES N. CLARK
Nevada Bar No. 13848
10040 W. Cheyenne Ave., Suite 170-109
Las Vegas, NV 89129

/s/
ANDREW HENRY PASTWICK
Nevada Bar No. 9146
1810 E. Sahara Avenue
Suite 120
Las Vegas, NV 89104
702-866-9978
Fax: [phone]
LAW OFFICES OF MICHAEL K. SUH & Email: [e-mail]
ASSOCIATES
EDWARD W. SUH
CA Bar No. 265356
Admitted Pro Hac Vice
3810 Wilshire Boulevard, Suite 1212
Los Angeles, Ca 90010
Attorneys for Plainitffs

IT IS SO ORDERED:
____________________________________
UNITED STATES MAGISTRATE JUDGE
December 9, 2016
DATED: __________________

IT IS HEREBY ORDERED that a pretrial conference is scheduled for 1:00 p.m., December 12,
2016, in Courtroom 3D.

CERTIFICATE OF SERVICE
I hereby certify that on December 8, 2016, I electronically filed the foregoing
STIPULATED REQUEST FOR PRETRIAL CONFERENCE AND REQUEST FOR
TELEPHONIC PARTICIPATION (FIRST REQUEST) with the Clerk of Court for the U.S.
District Court, District of Nevada by using the Court’s CM/ECF system. Participants in the case
who are registered CM/ECF users will be served by the CM/ECF system.

/S/ MILES N. CLARK
KNEPPER & CLARK LLC