Oliver v. Bell Trans et al
Filing
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ORDER. Based on 52 the parties' stipulation and good cause appearing, IT IS HEREBY ORDERED that the stipulation is approved. The stay is extended (nunc pro tunc from 11/13/17) to 1/9/2018. If the stipulation and order to dismiss is not filed by 1/9/18, the parties must appear for a status conference on 1/12/18 at 9:30 a.m. If the stipulation and dismissal order is timely filed, it should include the instruction to vacate this status conference. Signed by Judge Jennifer A. Dorsey on 12/7/2017. (Copies have been distributed pursuant to the NEF - MR)
Case 2:16-cv-00305-JAD-PAL Document 52 Filed 12/05/17 Page 1 of 3
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LEON GREENBERG, ESQ., SBN 8094
DANA SNIEGOCKI, ESQ., SBN 11715
Leon Greenberg Professional Corporation
2965 South Jones Blvd- Suite E3
Las Vegas, Nevada 89146
Tel (702) 383-6085
Fax (702) 385-1827
leongreenberg@overtimelaw.com
dana@overtimelaw.com
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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CAMERON E. OLIVER, Individually and on
behalf of others similarly situated,
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CASE NO.: 2:16-cv-00305-JAD-PAL
JOINT NOTICE OF SETTLEMENT
AND
STIPULATION AND ORDER TO
STAY ALL PROCEEDINGS
(NINTH REQUEST)
(Fifth Request Regarding Submission of
Settlement Documents)
Plaintiff,
vs.
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BELL TRANS, a Nevada Corporation, and
BRENT J. BELL,
Defendants.
ECF No. 52
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Plaintiff Cameron E. Oliver, (“Plaintiff”) and Defendants Bell Trans and Brent J. Bell
(collectively, “Bell Trans” or “Defendants”), through their counsel of record, submit the below
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stipulation to extend the stay of all proceedings in the above captioned matter. On June 19, 2017,
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after being notified that the parties had agreed to settle, on a collective and class-wide basis, all
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disputes and claims related to this litigation and related litigation (“Related Litigation”) (Case
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No. 2:15-cv-01066-MMDPAL, Willie Thurmond v. Presidential Limousine), the Court granted
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the parties’ stipulation to stay this matter until July 27, 2017 in order to allow the parties time to
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set forth in greater detail the terms of the parties’ settlement, as well as to allow Plaintiff’s
counsel time to file a motion seeking the Court’s approval of the settlement terms. ECF No. 45.
The Court extended that requested stay pursuant to the parties’ further stipulations and orders,
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Case 2:16-cv-00305-JAD-PAL Document 52 Filed 12/05/17 Page 2 of 3
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the most recent such order continuing the stay of this matter until November 13, 2017. ECF No.
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51. The primary reason for the instant extension is to allow the parties to finalize separate
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settlement agreements for this matter and the Related Litigation. While the parties had reached
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an agreement on all of the necessary substantive terms of a resolution of this case and the
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Related Litigation, they had to resolve various unanticipated, and potentially complex,
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procedural and mechanical issues regarding how those agreements would be structured and
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presented to the Court. To that end, the parties require additional time and respectfully stipulate
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as follows:
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The parties agree to stay all proceedings in the above captioned matter for a period of 48
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additional days beyond the current stay, which ended on November 13, 2017, to allow for the
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preparation and finalization of appropriate settlement documents. As set forth herein, this is the
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parties’ fifth request to stay this matter for the purpose of memorializing their negotiations into
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settlement documents. If this stipulation is granted, the current stay shall be extended until
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Tuesday, January 9, 2017.
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The forgoing request for stay is made in good faith not for the purpose of delay.
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///
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///
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Case 2:16-cv-00305-JAD-PAL Document 52 Filed 12/05/17 Page 3 of 3
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Dated: December 5, 2017
Dated: December 5, 2017
Respectfully submitted,
Respectfully submitted,
/s/ Leon Greenberg
LEON GREENBERG, ESQ.
DANA SNIEGOCKI, ESQ.
LEON GREENBERG
PROFESSIONAL CORPORATION
2965 South Jones Blvd., #E3
Las Vegas, NV 89146
Tel (702) 383-6085
Fax (702) 385-1827
Attorneys for Plaintiffs
/s/ Peter Navarro
ANTHONY L. HALL, ESQ.
PETER NAVARRO, ESQ.
HOLLAND & HART LLP
5441 Kietzke Lane, Second Floor
Reno, NV 89511
Tel: (775) 327-3000
Fax: (775) 786-6169
Attorneys for Defendants
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ORDER
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ITBased ORDERED:
IS SO on the parties' stipulation [ECF No. 52] and good cause appearing, IT IS
HEREBY ORDERED that the stipulation is approved. The stay is extended
(nunc pro tunc from 11/13/17) to January 9, 2018. If the stipulation and order to
dismiss is not filed by 1/9/18, the parties must appear for a status conference on
1/12/18 at 9:30 a.m. If the stipulation and dismissal order is timely filed, it should
United States District Judge
include the instruction to vacate this status conference.
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___________________________________
U.S. District Judge Jennifer Dorsey
December 7, 2017
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