Oliver v. Bell Trans et al

Filing 53

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 [phone]
Fax [phone]
[e-mail]
[e-mail]

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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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///

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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 [phone]
Fax [phone]
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: [phone]
Fax: [phone]
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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