Ringelberg v. Vanguard Integrity Professionals -Nevada, Inc. et al

Filing 211

ORDER Granting 209 Stipulation re Settlement and Stay of Litigation. The Parties shall have until 4/23/2019 to advise this Court of the final settlement between the Parties. The stipulation and order for dismissal shall be submitted to this court ten (10) days after. If the Parties are unable to reach a final settlement the Parties' Proposed Pre-trial Orders shall be submitted no later than 4/30/2019. Signed by Magistrate Judge Peggy A. Leen on 4/26/2019. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01788-JAD-PAL Document 209 Filed 04/18/19 Page 1 of 2

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J. Stephen Peek, Esq.
Nevada Bar No. 1758
Rachel L. Wise, Esq.
Nevada Bar No. 12303
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Vincent J. Aiello, Esq.
Nevada Bar No. 7970
GREENSPOON MARDER LLP
3993 Howard Hughes Parkway Ste. 400
Las Vegas, NV 89169
Phone: [phone]
Fax: [phone]
[e-mail]

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HOLLAND & HART LLP
9555 HILLWOOD DRIVE, 2ND FLOOR
LAS VEGAS, NV 89134

Attorneys for Defendants
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IN THE UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Plaintiff,

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Case No.: 2:17-cv-01788-JAD-PAL

STEVEN RINGELBERG,

STIPULATION AND ORDER
REGARDING SETTLEMENT AND STAY
OF LITIGATION

v.

VANGUARD INTEGRITY
18 PROFESSIONALS - NEVADA, INC., a
Nevada corporation, VANGUARD
19 INTEGRITY PROFESSIONALS, INC., a
Nevada corporation; DOES 1-10; and ROE
20 ENTITIES 11-20,
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Defendants.

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On March 29, 2019, Steven Ringelberg (the “Plaintiff”), and Vanguard Integrity

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Professionals – Nevada, Inc., Vanguard Integrity Professionals, Inc. (collectively, the

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“Defendants”), submitted a Joint Status Report stating that the parties reached the economic terms

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of settlement. ECF No. 207. Consistent with the Joint Status Report, the Parties continue to

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Case 2:17-cv-01788-JAD-PAL Document 209 Filed 04/18/19 Page 2 of 2

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negotiate settlement terms in good faith. The Parties are close to settlement but need additional

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time to finalize all terms.

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THEREFORE, the Parties, by and through their undersigned counsel, stipulate and agree
as follows:
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The Parties shall have until April 23, 2019, to advise this Court of the final

settlement between the Parties.
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The stipulation and order for dismissal shall be submitted to this court ten (10) days

after April 23, 2019.1
3.

If the Parties are unable to reach a final settlement, the Parties’ Proposed Pre-trial

Orders shall be submitted no later than April 30, 2019.

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HOLLAND & HART LLP
9555 HILLWOOD DRIVE, 2ND FLOOR
LAS VEGAS, NV 89134

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RESPECTFULLY SUBMITTED this 18th day of April, 2019.

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By: /s/ J. Stephen Peek, Esq.
J. Stephen Peek, Esq.
Rachel L. Wise, Esq.
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, Nevada 89134

By: /s/ Richard A. Mescon, Esq.
Richard A. Mescon, Esq.
LEICHTMAN LAW PLLC
Three Park Avenue, 15th Floor
New York, NY 10016

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Vincent J. Aiello, Esq.
GREENSPOON MARDER LLP
3993 Howard Hughes Parkway Ste. 400
Las Vegas, NV 89169

Daniel Norr, Esq.
LAW OFFICE OF DANIEL NORR, LLC
170 S. Green Valley Parkway, Ste 300
Henderson, NV 89012

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Attorneys for Defendants

Attorneys for Plaintiff

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IT IS SO ORDERED.

_________________________________
PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE

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Dated this 26th day of April, 2019.

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Based on Mr. Ringelberg’s rights under the Age Discrimination in Employment Act of
1967 (“ADEA”) and the Older Workers Benefit Protection Act (“OWBPA”) (the “Acts”), the
Parties choose to allow the Defendants ten (10) days to effectuate the settlement payment.
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