Rogers v. National Security Technologies, LLC

Filing 29

ORDER Granting 28 Stipulation to Extend Time. Settlement documents are due by 2/28/2019. Signed by Magistrate Judge Nancy J. Koppe on 1/24/2019. (Copies have been distributed pursuant to the NEF - ADR)

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Case 2:18-cv-00278-JAD-NJK Document 28 Filed 01/24/19 Page 1 of 2 1 2 3 4 JAMES P. KEMP, ESQ. Nevada Bar No. 6375 KEMP & KEMP 7435 W. Azure Drive, Suite 110 Las Vegas, Nevada 89130 Ph. (702) 258-1183 / Fax (702) 258-6983 jp@kemp-attorneys.com Attorney for Plaintiff TRACY ROGERS 5 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 8 TRACY ROGERS, 9 10 Case No. 2:18-cv-00278-JAD-NJK Plaintiff, STIPULATION AND ORDER TO EXTEND TIME RE: SETTLEMENT vs. ATTORNEYS AT LAW 7435 W. AZURE DR., SUITE 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 11 NATIONAL SECURITY TECHNOLOGIES, LLC, a Delaware Limited Liability Company; 12 oDoes I-X; Roe Corporations I-X, 13 Defendants. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Pursuant to the court’s January 14, 2019 Order (ECF No. 27) Plaintiff TRACY ROGERS, and Defendant NATIONAL SECURITY TECHNOLOGIES, LLC, by and through their respective attorneys of record hereby stipulate and request the court to approve an extension of time to submit a notice of settlement, dismissal paperwork, or Proposed Joint PreTrial Order through and including February 28, 2019. The Parties stipulate and represent as follows: 1. The Parties have reached a resolution of the case by and between themselves; 2. The Plaintiff is presently a Debtor in a Chapter 13 Bankruptcy Case in the District of Nevada (#BK-S-18-10483-MKN); 3. As a result of the Plaintiff’s pending bankruptcy reorganization the approval of the settlement must be obtained from the Bankruptcy Court; 4. A motion seeking approval is pending a hearing on January 30, 2019 at 2:30 p.m. before the Honorable Mike Nakagawa in Bankruptcy Court; 28 1 Case 2:18-cv-00278-JAD-NJK Document 28 Filed 01/24/19 Page 2 of 2 1 2 3 4 5 6 7 8 9 10 11 ATTORNEYS AT LAW 7435 W. AZURE DR., SUITE 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 13 5. The Plaintiff has represented to Defendant that there is no anticipated problems with obtaining the approval of the Bankruptcy Court and to Plaintiff’s knowledge, based upon a review of the Bankruptcy Court docket, there have not been any objections or oppositions filed to the request to employ Plaintiff’s counsel and to approve the settlement; 6. Everything else to satisfy the settlement terms has been completed and a proposed order of dismissal has been drafted. As soon as approval from the Bankruptcy Court is obtained the Parties will be submitting the dismissal papers; 7. The Parties estimate, in good faith, that this matter will be concluded by February 28, 2019 and stipulate and request that the court extend the time to submit notice of settlement, dismissal papers, or a Proposed Joint Pre-Trial Order through February 28, 2019. . 14 15 16 DATED this 23rd day of January 2019. DATED this 23rd day of January 2019. JACKSON LEWIS P.C. KEMP & KEMP 17 18 19 /s/ Joshua A. Sliker, Esq. Joshua A. Sliker, Esq. Attorneys for Defendant /s/ James P. Kemp, Esq. James P. Kemp, Esq. Attorneys for Plaintiff 20 21 22 IT IS SO ORDERED. 23 24 _____________________________________ UNITED STATES MAGISTRATE JUDGE 25 DATED: 26 27 28 2 January 24, 2019

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