Ward v. State of Nevada Board, ex rel, et al

Filing 48

ORDER Granting 47 Stipulation Regarding Stay Pending Dismissal. The case is STAYED in its entirety, including but not limited to all deadlines related to pleadings, responses to pleadings and any and all deadlines set in the 34 Stipulated Discovery Plan through and including 6/30/2018. Signed by Judge Jennifer A. Dorsey on 4/9/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-03029-JAD-NJK Document 47 Filed 04/06/18 Page 1 of 4

S. BRETT SUTTON, 12109
1 [e-mail]
JARED HAGUE, 12761
2 [e-mail]
ANTHONY E. GUZMAN II, 14373
3 [e-mail]
SUTTON HAGUE LAW CORPORATION, P.C.
4 6671 S. Las Vegas Blvd., Suite 210
Las Vegas, Nevada 89119
5 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants:
7 STATE OF NEVADA, ex rel. its BOARD OF MEDICAL EXAMINERS,
PAMELA CASTAGNOLA, KIM FRIEDMAN,
8 KATI PAYTON, TODD RICH and EDWARD COUSINEAU
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LARA WARD, an individual,
Plaintiff,

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Case No.: 2:17-cv-03029-JAD-NJK
STIPULATION AND [PROPOSED]
ORDER REGARDING STAY PENDING
DISMISSAL

vs.
STATE OF NEVADA, ex rel. its BOARD
OF MEDICAL EXAMINERS, DON
ANDREAS, an Individual, PAMELA
CASTAGNOLA, an Individual, KIM
FRIEDMAN,
an
Individual,
KATI
PAYTON, an Individual, TODD RICH, an
Individual, AND EDWARD COUSINEAU,
an Individual; DOES I - X,

Complaint Filed: December 11, 2017
Trial Date: None set

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Defendants.

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Plaintiff, LARA WARD (“Plaintiff”) and Defendants, STATE OF NEVADA, ex rel. its

24 BOARD OF MEDICAL EXAMINERS, PAMELA CASTAGNOLA, KIM FRIEDMAN, KATI
25 PAYTON, DON ANDREAS, and EDWARD COUSINEAU (“Defendants”) (jointly the “P
26 arties”) by and through their respective attorneys of record, hereby stipulate and agree as
27 follows:
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STIPULATION AND [PROPOSED] ORDER TO STAY ACTION PENDING DISMISSAL

Case 2:17-cv-03029-JAD-NJK Document 47 Filed 04/06/18 Page 2 of 4

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WHEREAS, the Parties attended an Early Neutral Evaluation session on March 30, 2018

2 before the Honorable Peggy A. Leen, United States Magistrate Judge and reached the terms of an
3 agreement that would resolve the instant action in its entirety, which terms are generally
4 described in a minute order issued by Judge Leen at ECF No. 46, including an agreement that
5 Plaintiff shall continue receiving her salary and health benefits through and including June 1,
6 2018;
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WHEREAS, the Parties are in the process of preparing a long-form Settlement

8 Agreement and Release and desire to avoid expenditure of additional time and resources pending
9 the drafting and execution of the Settlement Agreement in light of the pending deadlines in the
10 action;
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THEREFORE, the Parties hereby stipulate and respectfully request that the Court enter

12 an order that the case is STAYED in its entirety, including but not limited to all deadlines related
13 to pleadings, responses to pleadings and any and all deadlines set forth within the Stipulated
14 Discovery Plan at ECF No. 34, through and including June 30, 2018, by which time the Parties
15 anticipate that all preconditions and requirements for Plaintiff to submit a stipulated dismissal
16 with prejudice will have been performed by the Parties.
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Date: April 6, 2018

SUTTON HAGUE LAW CORPORATION, P.C.

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By:

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/s/ Jared Hague
S. BRETT SUTTON
JARED HAGUE
ANTHONY E. GUZMAN II
Attorneys for Defendants
STATE OF NV BOARD OF MEDICAL
EXAMINERS, PAMELA CASTAGNOLA,
KIM FRIEDMAN,
KATI PAYTON, and EDWARD
COUSINEAU

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STIPULATION AND [PROPOSED] ORDER TO STAY ACTION PENDING DISMISSAL

Case 2:17-cv-03029-JAD-NJK Document 47 Filed 04/06/18 Page 3 of 4

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Date: April 6, 2018

GARG GOLDEN LAW FIRM

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By:

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/s/ Anthony Golden
ANTHONY GOLDEN
Attorneys for Defendants
DON ANDREAS

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Date: April 6, 2018

HKM EMPLOYMENT ATTORNEYS, LLP

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By:
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/s/ Jenny L. Foley
JENNY L. FOLEY
Attorney for Plaintiff
LARA WARD

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STIPULATION AND [PROPOSED] ORDER TO STAY ACTION PENDING DISMISSAL

Case 2:17-cv-03029-JAD-NJK Document 47 Filed 04/06/18 Page 4 of 4

ORDER
[PROPOSED] ORDER

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GOOD CAUSE APPEARING, it is hereby ORDERED, ADJUDGED, AND DECREED

3 that the case is STAYED in its entirety, including but not limited to all deadlines related to
4 pleadings, responses to pleadings and any and all deadlines set forth within the Stipulated
5 Discovery Plan at ECF No. 34, through and including June 30, 2018.
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IT IS SO ORDERED.

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Dated: April 9, 2018.

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Date: April ___, 2018

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UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER TO STAY ACTION PENDING DISMISSAL