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)

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Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 Page 1 of 3 1 2 3 4 5 6 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 7 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 11 CAMERON E. OLIVER, Individually and on behalf of others similarly situated, Plaintiff, 12 13 14 15 16 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. 17 18 19 Plaintiff Cameron E. Oliver, (“Plaintiff”) and Defendants Bell Trans and 20 21 22 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 23 24 25 26 27 28 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 1 Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 Page 2 of 3 1 2 3 4 5 6 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 7 8 9 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 10 11 12 13 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, 14 15 16 and potentially complex, procedural and mechanical issues regarding how those agreements would be structured and presented to the Court. 17 18 19 20 21 22 23 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 24 25 26 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 27 28 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 2 Case 2:16-cv-00305-JAD-PAL Document 54 Filed 01/10/18 Page 3 of 3 1 2 3 4 5 6 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 7 8 faith not for the purpose of delay. 9 10 11 12 13 14 Dated January 10, 2018 Dated January 10, 2018 15 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/ Anthony Hall 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 16 17 18 19 20 21 22 ORDER 23 24 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. 25 26 27 28 United States District Judge January 11, 2018 3

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