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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1 6 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.: (702) 405-8100 Fax No.: (702) 405-8101 pitegoff@morrissullivanlaw.com cereghino@morrissullivanlaw.com 7 Attorneys for Defendants 2 3 4 5 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 13 BEVERLY J. WATKINS, an individual, Plaintiff, vs. 14 15 16 17 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. 18 19 20 Plaintiff BEVERLY WATKINS and Defendant UNIVERSITY MEDICAL CENTER 21 (“UMC”), by their undersigned counsel of record, hereby stipulate and agree to stay the 22 proceedings in this case pending approval by Defendant’s Governing Board of a proposed 23 settlement. 24 25 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 26 27 28 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 - Page 1 of 3 - 1 2 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). 3 The short stay is not intended to unduly delay the case but rather to save the parties from 4 expending further fees and costs in proceeding with discovery while the settlement is pending 5 review. 6 7 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. 8 9 10 11 12 13 14 15 /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 16 ORDER 17 18 IT IS HEREBY ORDERED that all proceedings shall be stayed until August 30, 2017, to 19 allow Defendant’s Board to review, consider and decide whether to adopt the proposed settlement. 20 IT IS ALSO ORDERED should the Board not approve settlement, the remaining discovery 21 deadlines in this matter shall be extended by 2 months, by a separate stipulation submitted by the 22 23 parties. IT IS SO ORDERED this 17th day of July, 2017: 24 25 26 ___________________________________________ UNITED STATES MAGISTRATE JUDGE 27 28 - Page 2 of 3 - 1 CERTIFICATE OF SERVICE 2 I DO HEREBY CERTIFY that service of the foregoing: STIPULATION AND ORDER 3 TO STAY THE CASE PENDING SETTLEMENT APPROVAL was made this 30th day of 4 June, 2017, by: 5 [ ] 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. [ ] 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. [ ] 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. 6 7 8 9 10 11 12 13 14 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: (702) 474-0523 Fax: (702) 474-0631 winderdanatty@aol.com Attorneys for Plaintiff 15 16 17 18 19 20 21 22 23 24 [ ] 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. 25 26 /s/ Victoria Grant__________________________ An Employee of MORRIS, SULLIVAN, LEMKUL & PITEGOFF 27 28 - Page 3 of 3 -

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