Oliver v. Bell Trans et al

Filing 55

ORDER granting 54 Stipulation. The stay is extended (nunc pro tunc from January 9, 2018) to February 8, 2018. IT IS FURTHER ORDERED that the parties appear for a Status Conference on 2/12/2018 at 03:00 PM in LV Courtroom 6D before Judge Jennifer A. Dorsey. Signed by Judge Jennifer A. Dorsey on 1/11/2018. (Copies have been distributed pursuant to the NEF - DC)

Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 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,
Plaintiff,

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CASE NO.: 2:16-cv-00305-JAD-PAL
JOINT NOTICE OF SETTLEMENT
AND
STIPULATION AND ORDER TO
STAY ALL PROCEEDINGS
(TENTH REQUEST)
(Sixth Request Regarding Submission of
Settlement Documents)

vs.
BELL TRANS, a Nevada Corporation, and
BRENT J. BELL,
Defendants.

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Plaintiff Cameron E. Oliver, (“Plaintiff”) and Defendants Bell Trans and

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Brent J. Bell (collectively, “Bell Trans” or “Defendants”), through their counsel of
record, submit the below stipulation to extend the stay of all proceedings in the

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above captioned matter. On June 19, 2017, after being notified that the parties had
agreed to settle, on a collective and class-wide basis, all disputes and claims related
to this litigation and related litigation (“Related Litigation”) (Case No. 2:15-cv01066-MMDPAL, Willie Thurmond v. Presidential Limousine), the Court granted
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Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 Page 2 of 3

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the parties’ stipulation to stay this matter until July 27, 2017 in order to allow the
parties time to 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, the most recent such order

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continuing the stay of this matter until January 9, 2018. ECF No. 53. 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 an agreement on all of the necessary substantive terms of a resolution
of this case and the Related Litigation, they had to resolve various unanticipated,

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and potentially complex, procedural and mechanical issues regarding how those
agreements would be structured and presented to the Court.

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The parties were having difficulties resolving the foregoing issues. Within
the past two days, the parties have made substantial process and conferred and
communicated about what they hope is the resolution of all of the issues necessary
to finalize the settlement and prepare a stipulation of settlement for the Court’s

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review. Based upon plaintiff’s counsel’s communication of January 10, 2018 with
court staff member, Danielle, the parties are jointly submitting this stipulation to

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extend the current stay, nunc pro tunc, for a period of 30 days from January 9,
2018 through February 8, 2018. The parties are also mindful that the Court will be
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Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 Page 3 of 3

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setting a status check at which the parties are expected to appear some time after
the expiration of the requested stay on February 8, 2018. The parties aim to, and
are hopeful they will, have a motion filed with the Court seeing preliminary
approval of their proposed settlement prior to February 8, 2018.
Based upon the forgoing, the request for a continued stay is made in good

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faith not for the purpose of delay.

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Dated January 10, 2018

Dated January 10, 2018

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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/ Anthony Hall
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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IT IS SO ORDERED:

Based on the parties' stipulation [ECF No.
54] and good cause appearing, IT IS
ORDERED that the stipulation is granted.
The stay is extended (nunc pro tunc from
January 9, 2018) to February 8, 2018. IT IS
FURTHER ORDERED that the parties
appear for a status conference on February
12, 2018 at 3:00 p.m.

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United States District Judge
January 11, 2018

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