Vegas Game Point, LLC v. JPMorgan Chase Bank, N.A.

Filing 13

ORDER Granting 11 Stipulation for Dismissal of Non-UCC Claims against Defendant JPMorgan Chase Bank, N.A. without prejudice. Signed by Judge Robert C. Jones on 2/3/16. (Copies have been distributed pursuant to the NEF - PS)

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Michael N. Poli, #005461
[e-mail]
POLI & BALL, P.L.C.
400 South 4th Street, Suite 500
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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VEGAS GAME POINT, LLC, a Nevada
limited liability company,
Plaintiff,

POLI & BALL, P.L.C.
400 SOUTH 4TH STREET, SUITE 500
LAS VEGAS, NEVADA 89101
[phone]

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Case No.: 2:15-CV-02274

vs.
JPMORGAN CHASE BANK, N.A, d/b/a
CHASE BANK, a national association,

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Defendant.
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STIPULATION FOR DISMISSAL OF NON-UCC CLAIMS AGAINST
DEFENDANT JPMORGAN CHASE BANK, N.A. WITHOUT PREJUDICE
Through their respective counsel, Plaintiff Vegas Game Point, LLC and
Defendant JPMorgan Chase Bank, N.A. hereby stipulate and agree that the following
claims set forth in the Complaint filed by Plaintiff Vegas Game Point, LLC on or about
November 5, 2015 shall be dismissed without prejudice:

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Breach of Contract (First Claim for Relief);
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Tortious Breach of the Implied Covenant of Good Faith and Fair Dealing
(Second Claim for Relief);

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Breach of Fiduciary Duty (Third Claim for Relief);

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Negligence (Fourth Claim for Relief);

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Fraud (Fifth Claim for Relief); and

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Preliminary and Permanent Injunction (Sixth Claim for Relief)

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(collectively, the “non-UCC Claims”).

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By way of this Stipulation, the sole claim remaining is Plaintiff’s claim alleging Failure

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to Exercise Ordinary Care as Required under the UCC (the “UCC Claim”).1

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Defendant’s counsel certifies that Plaintiff’s counsel has reviewed and approved

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this Stipulation, and that Plaintiff’s counsel has authorized Defendant’s counsel to sign

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and file on his behalf.

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RESPECTFULLY SUBMITTED this 15th day of January 2016.
NEWMAN LAW, LLC

POLI & BALL, P.L.C.

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POLI & BALL, P.L.C.
400 SOUTH 4TH STREET, SUITE 500
LAS VEGAS, NEVADA 89101
[phone]

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By /s/ Richard Newman (with permission) By /s/ Michael N. Poli
Richard Newman
Michael N. Poli
Attorney for Vegas Game Point, LLC
Attorneys for JPMorgan Chase Bank, N.A.

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ORDER
IT IS SO ORDERED:

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DATED: _________________

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_______________________________________
UNITED STATES DISTRICT COURT JUDGE

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Although the Complaint identifies it as the Ninth Claim for Relief, it is actually
the Seventh Claim for Relief.
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AFFIRMATION

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Pursuant to NRS 239B.030
The undersigned does hereby affirm that the preceding document, filed in this

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case:
Document does not contain the social security number of any person.
- ORDocument contains the social security number of a person as required by:
A specific state or federal law, to wit:

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POLI & BALL, P.L.C.
400 SOUTH 4TH STREET, SUITE 500
LAS VEGAS, NEVADA 89101
[phone]

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________________________________________
(State specific state or federal law)

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- or 11

For the administration of a public program.
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- or 13

For an application for a federal or state grant.
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- or 15
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Confidential Family Court Information Sheet
(NRS 125.130, NRS 125.230, NRS 125B.255)

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DATED this 15th day of January 2016.
POLI & BALL, P.L.C.

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By /s/ Michael N. Poli
Michael N. Poli
400 South 4th Street, Suite 500
Las Vegas, Nevada 89101
Attorneys for Defendant
JPMorgan Chase Bank, N.A.

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CERTIFICATE OF SERVICE
I hereby certify that on the 15th day of January, 2016, a true and correct copy of
the foregoing was sent to the following, by postage-prepaid mail:

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Richard Newman, Esq.
NEWMAN LAW, LLC
365 E. Pilot Rd, Suite C
Las Vegas, Nevada 89119
Attorneys for Plaintiff

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POLI & BALL, P.L.C.
400 SOUTH 4TH STREET, SUITE 500
LAS VEGAS, NEVADA 89101
[phone]

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By

/s/ Linda Lieber
Employee of Poli & Ball

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S:\LKL\Chase\VegasGame\Plead\Stip to Ext DL Answer.doc

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