Guo v. Bottega Veneta, Inc. et al

Filing 25

ORDER granting ECF No. 24 Stipulation to Excuse Attendance of Rocky Claar and Carlos Delos Reyes from Personal Attendance at ENE Session. Signed by Magistrate Judge George Foley, Jr on 3/29/2018. (Copies have been distributed pursuant to the NEF - LH)

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ROBERT S. LARSEN, ESQ.
Nevada Bar No. 7785
GORDON REES SCULLY MANSUKHANI, LLP
300 South Fourth Street, Suite 1550
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendants
Bottega Veneta, Inc., Rocky Claar
and Carlos Delos Reyes

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
EDGAR GUO, an individual,

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300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

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)
)
Plaintiff,
)
)
vs.
)
)
BOTTEGA VENETA, INC., a corporation; ROCKY )
CLAAR, an individual; CARLOS DELOS REYES, )
an individual; DOES I – V, and ROES VI – X,
)
)
Defendants.
)
)

Case No.: 2:17-cv-02778-MMD-PAL

STIPULATION AND ORDER TO
EXCUSE ATTENDANCE OF
ROCKY CLAAR AND CARLOS
DELOS REYES FROM
PERSONAL ATTENDANCE AT
ENE SESSION

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Pursuant to Local Rules 6-1 and 7-1, Plaintiff EDGAR GUO (“Plaintiff”), and

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Defendants ROCKY CLAAR and CARLOS DELOS REYES (“Defendants”), by and through

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their respective attorneys of record, stipulate as follows:

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STIPULATION
1.

Defendant Bottega Veneta was Plaintiff’s employer and the primary employment

based claims in the Complaint are brought against Bottega Veneta.
2.

Defendant Carlos Delos Reyes is currently employed by Defendant Bottega

Veneta.
3.

During preparation for written discovery responses and the ENE conference,

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counsel for Defendants learned that Mr. Reyes is currently on extended medical leave from the

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Company following a recent surgery.
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4.

Mr. Reyes has requested that he be excused from personal attendance at the ENE

Conference.

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5.

Plaintiff does not object to Mr. Reyes’ request that he not be required to attend the

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ENE Conference provided that Mr. Reyes has given full authority to counsel or Bottega Veneta

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to resolve this matter at the ENE Conference.

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6.

Mr. Reyes agrees that he will give full authority to either his counsel or Bottega

Veneta to resolve this matter at the ENE Conference if he is not required to attend.
7.

Defendant Rocky Claar is also an employee of Bottega Veneta.

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8.

Mr. Claar currently works and resides in King of Prussia, Pennsylvania.

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9.

Mr. Claar has also requested that he be excused from personal attendance at the

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300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

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ENE Session as long-distance travel is inconvenient and will take significant time away from his

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work and family responsibilities.

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10.

Bottega Veneta supports Mr. Claar’s request as Bottega Veneta is already

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expending significant funds in the amount of travel costs to bring a representative to the ENE

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Conference. Adding the travel expense of Mr. Claar and the lost time from his work

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responsibilities adds a significant burden to Bottega Veneta.

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Plaintiff does not object to Mr. Claar’s request that he not be required to attend

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the ENE Conference provided that Mr. Claar has given full authority to counsel or Bottega

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Veneta to resolve this matter at the ENE Conference.

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12.

Mr. Claar agrees that he will give full authority to either his counsel or Bottega

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Veneta to resolve this matter at the ENE Conference if he is not required to attend.

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13.

This stipulation is not made for purposes of delay and will serve judicial economy

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of the Defendants.

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DATED: March 28, 2018.

DATED: March 28, 2018.

GORDON REES SCULLY MANSUKHANI,
LLP

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

/s/ Robert S. Larsen
ROBERT S. LARSEN, ESQ.
Nevada Bar No. 7785
300 South Fourth Street, Suite 1550
Las Vegas, Nevada 89101

/s/ Kristina Miletovic
Dan M. Winder, Esq.
Kristina Miletovic, Esq.
3507 W. Charleston Blvd.
Las Vegas, NV 89102

Attorneys for Bottega Veneta, Inc.

Attorneys for Plaintiff

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300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

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ORDER
IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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1147303/37413047v.1

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3/29/2018