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

Filing 108

ORDER Granting 107 Stipulation to Strike and Replace Exhibits. The Clerk of Court is directed to seal ECF Nos. 103 -18 and 103 -26 and replace them with the redacted exhibits attached in ECF No. 107 . Signed by Magistrate Judge Cam Ferenbach on 4/10/17. (Copies have been distributed pursuant to the NEF - ADR)

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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]

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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]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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RAMA SOU; TAI BUI;
SCOTT ZIMMERMAN,

Case No. 2:15-cv-00698-APG-VCF

and

STIPULATION AND [PROPOSED]
ORDER TO STRIKE AND
REPLACE EXHIBITS

Plaintiffs,
v.

[LR IC 6-1]

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

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Stipulation to Strike and Replace Exhibits

2:15-cv-00698-APG-VCF

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TO THE HONORABLE COURT, ALL PARTIES, AND THEIR
COUNSEL OF RECORD:

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Plaintiffs Rama Sou, Tai Bui, and Scott Zimmerman (collectively,

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“Plaintiffs”), on the one hand, and defendants Michael Bash, Jeremy Bash,

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Berkley Enterprises, Inc., Pepperdine Enterprises, Inc., Ninety-Five Fort Apache

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Complex, LLC, and Royal View, LLC (collectively, “Defendants”), on the other

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hand, by and through their respective counsel, hereby stipulate as follows:

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WHEREAS, on March 20, 2017, Plaintiffs filed a Motion for Summary
Judgment against Jeremy Bash, and included certain exhibits with the Motion;

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WHEREAS, on April 7, 2017, Defendants’ counsel brought to Plaintiffs’

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counsel’s attention that certain exhibits contained information that should have

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been redacted;

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WHEREAS, in light of the aforesaid, and in the interests of equity and

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judicial economy, the parties agree to allow Plaintiffs to strike the non-compliant

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exhibits and to replace the exhibits with those that have been properly redacted;

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the

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parties, through their respective counsel of record, that good cause exists and it is

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in the best interests of all parties that:

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sealed

(1) ECF Docket 103.18 and 103.26 shall be struck, and replaced by the
103-18

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103-28

redacted exhibits attached hereto.

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IT IS SO STIPULATED.

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Dated:

April 17, 2017

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LAW OFFICES OF MICHAEL K. SUH &
ASSOCIATES

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By: ___/s/ Edward W. Suh____________
Edward W. Suh

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Stipulation to Strike and Replace Exhibits

2:15-cv-00698-APG-VCF

CA Bar No. 265356
Admitted Pro Hac Vice

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Miles N. Clark
NV Bar No. 13848
KNEPPER & CLARK LLC

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Attorneys for Plaintiffs
Rama Sou, Tai Bui, and Scott
Zimmerman

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Dated:

April 17, 2017

LAW OFFICE OF ANDREW H.
PASTWICK L.L.C.

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By: ___/s/ Andrew H. Pastwick________

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Andrew H. Pastwick
NV Bar No. 009146
LAW OFFICE OF ANDREW H.
PASTWICK L.L.C.

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Attorneys for Defendants
Michael Bash, Jeremy Bash, Berkley
Enterprises, Inc., Pepperdine Enterprises,
Inc., Ninety-Five Fort Apache Complex,
LLC, and Royal View, LLC

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The Clerk of Court is directed to seal ECF Nos. 103-18 and 103-26 and replace them with the
redacted exhibits attached in ECF No. 107.

IT IS SO ORDERED:

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____________________________________
UNITED STATES MAGISTRATE JUDGE

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4-10-2017
DATED: __________________

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Stipulation to Strike and Replace Exhibits

2:15-cv-00698-APG-VCF