Simmons v. Verizon Management Pension Plan

Filing 40

ORDER re 39 Case Management Report. The deadline to file dismissal documents or a joint status report explaining why dismissal documents have not been filed is extended to 2/17/2017. Signed by Chief Judge Gloria M. Navarro on 1/31/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-00455-GMN-GWF Document 39 Filed 01/26/17 Page 1 of 2

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Patricia S. Waldeck, Nev. Bar No. 2640
777 N. Rainbow Blvd., Suite 270-S
Las Vegas, NV 89107
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Kirsten G. Scott, Cal. Bar. No. 253464 (Admitted Pro Hac Vice)
RENAKER HASSELMAN SCOTT LLP
235 Montgomery St., Suite 944
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOHN SIMMONS, SR.,

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Case No. 2:16-CV-00455-GMN-GWF

Plaintiff,
JOINT STATUS REPORT REGARDING
SETTLEMENT

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vs.

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VERIZON MANAGEMENT PENSION PLAN,

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Defendants.

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On December 22, 2016, following a Settlement Conference with Magistrate Judge
George Foley, Jr., Plaintiff John Simmons, Sr. (“Simmons”) and Defendant Verizon
Management Pension Plan (“Plan”), reached agreement on a dollar amount to settle all claims
and causes of action in the above-referenced action. Counsel for the Plan indicated that she
would send a draft settlement agreement for Simmons’ review.
On January 13, 2017, the Plan provided Simmons with a draft agreement. After some

JOINT STATUS REPORT REGARDING SETTLEMENT

CASE NO. 2:16-CV-00455-GMN-GWF

Case 2:16-cv-00455-GMN-GWF Document 39 Filed 01/26/17 Page 2 of 2

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discussion and edits to the content of the agreement, Simmons and his counsel provided a signed
and notarized copy of the agreement on January 25, 2017.
Per the terms of the agreement, the Plan will now send Simmons a pension election form,
and following return of that document, the Plan will provide to Simmons the agreed-upon
settlement amount. The Plan estimates that this can be completed promptly. It is important to
Simmons that he receive the agreed-upon settlement payment before dismissing this case.
For these reasons, the parties respectfully request that the Court extend the current
deadline to file dismissal documents from January 30, 2017 to February 17, 2017, by which
time the parties shall dismiss the case, or file a joint case management conference statement
explaining why the case has not been dismissed.
Dated: January 26, 2017

Respectfully submitted,

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RENAKER HASSELMAN SCOTT LLP

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By:

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___/s/ Kirsten Scott______________

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Kirsten Scott

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Attorneys for Plaintiff

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Dated: January 26, 2017

Respectfully submitted,
LEWIS ROCA ROTHGERBER CHRISTIE LLP

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By:

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___/s/ Ann-Martha Andrews

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Ann-Martha Andrews

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Attorneys for Defendant

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ORDER

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IT IS HEREBY ORDERED that the
deadline to file dismissal documents or a
joint status report explaining why
dismissal documents have not been filed
is extended to February 17, 2017.

____________________________________
UNITED STATES DISTRICT JUDGE
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DATED this ____ day of January, 2017.

JOINT STATUS REPORT REGARDING SETTLEMENT

CASE NO. 2:16-CV-00455-GMN-GWF