Watkins v. University Medical Center

Filing 36

ORDER Granting 35 Stipulation to Stay the Case. Signed by Magistrate Judge Peggy A. Leen on 7/17/17. (Copies have been distributed pursuant to the NEF - MR)

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JEFFREY I. PITEGOFF, ESQ.
Nevada Bar No. 005458
DANIEL S. CEREGHINO, ESQ.
Nevada Bar No. 011534
MORRIS, SULLIVAN, LEMKUL & PITEGOFF
3770 Howard Hughes Parkway, Suite 170
Las Vegas, Nevada 89169
Telephone No.: [phone]
Fax No.: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA

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BEVERLY J. WATKINS, an individual,
Plaintiff,
vs.

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Case No: 2:16-cv-01105-APG-(PAL)

UNIVERSITY MEDICAL CENTER a.k.a.
UNIVERSITY MEDICAL CENTER OF
SOUTHERN NEVADA a.k.a. UMC, a
political subdivision of Nevada; DOES I-V;
ROES VI-X,

STIPULATION AND ORDER
TO
STAY THE CASE PENDING
SETTLEMENT APPROVAL

Defendants.

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Plaintiff BEVERLY WATKINS and Defendant UNIVERSITY MEDICAL CENTER

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(“UMC”), by their undersigned counsel of record, hereby stipulate and agree to stay the

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proceedings in this case pending approval by Defendant’s Governing Board of a proposed

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settlement.

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The parties in this case have reached a tentative settlement. However, the settlement terms
must be approved by Defendant University Medical Center of Southern Nevada’s Governing

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Board (hereinafter “Board”). The Board does not meet until August 23, 2017. As such, the parties
request a short stay of the discovery proceedings to allow the Board to consider and adopt the

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proposed settlement. The parties further stipulate that should this matter not lead to settlement, the
remaining discovery deadlines be extended by the duration of the stay (by 2 months).

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The short stay is not intended to unduly delay the case but rather to save the parties from

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expending further fees and costs in proceeding with discovery while the settlement is pending

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review.

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DATED this 30th day of June, 2017.

DATED this 30th day of June, 2017.

MORRIS, SULLIVAN, LEMKUL
& PITEGOFF

LAW OFFICE OF DAN M. WINDER, P.C.

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/s/ Jeffrey I. Pitegoff, Esq.
____________________
Jeffrey I. Pitegoff, Esq.
Nevada Bar No.: 5458
Daniel S. Cereghino, Esq.
Nevada Bar No. 011534
3770 Howard Hughes Pkwy, Suite 170
Las Vegas, NV 89169
Attorney for Defendant

/s/ Kristina Miletovic, Esq.
________________________
Dan M. Winder, Esq.
Nevada Bar No. 001569
Kristina Miletovic, Esq.
Nevada Bar No. 014089
3507 W. Charleston Blvd.
Las Vegas, NV 89102
Attorney for Plaintiff

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ORDER

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IT IS HEREBY ORDERED that all proceedings shall be stayed until August 30, 2017, to

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allow Defendant’s Board to review, consider and decide whether to adopt the proposed settlement.

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IT IS ALSO ORDERED should the Board not approve settlement, the remaining discovery

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deadlines in this matter shall be extended by 2 months, by a separate stipulation submitted by the

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parties.

IT IS SO ORDERED this 17th day of July, 2017:

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___________________________________________
UNITED STATES MAGISTRATE JUDGE

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CERTIFICATE OF SERVICE

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I DO HEREBY CERTIFY that service of the foregoing: STIPULATION AND ORDER

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TO STAY THE CASE PENDING SETTLEMENT APPROVAL was made this 30th day of

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June, 2017, by:

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BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in the United States mail at Las Vegas, Nevada, addressed
as set forth below.

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BY FACSIMILE: by transmitting via facsimile the document(s) listed above to the fax
number(s) set forth below on this date before 5:00p.m. pursuant to EDCR Rule 7.26(a).
A printed transmission record is attached to the file copy of this document.

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BY PERSONAL SERVICE: by causing personal delivery by an employee of MORRIS
SULLIVAN LEMKUL & PITETGOFF of the document(s) listed above to the person(s)
at the address (es) set forth below.

[X]

BY ELECTRONIC SERVICE: by transmitting via the Court’s electronic CM-ECF
filing services the document(s) listed above to the Counsel set forth below on this date
pursuant to FRCP Rules.

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KRISTINA MILETOVIC, ESQ.
Nevada State Bar No. 14089
DAN M. WINDER, ESQ
Nevada State Bar No. 1569
SCOTT C. DORMAN, ESQ.
Nevada State Bar No. 13108
LAW OFFICE OF DAN M. WINDER, P.C.
3507 W. Charleston Blvd.
Las Vegas, NV 89102
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff

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BY ELECTRONIC MAIL: by transmitting via the internet the document(s) listed
above to the email address listed in the Nevada Legal Directory to Counsel set forth
below on this date.

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/s/ Victoria Grant__________________________
An Employee of MORRIS, SULLIVAN, LEMKUL & PITEGOFF

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