Rogers v. National Security Technologies, LLC
Filing
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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)
Case 2:18-cv-00278-JAD-NJK Document 28 Filed 01/24/19 Page 1 of 2
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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
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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TRACY ROGERS,
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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
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NATIONAL SECURITY TECHNOLOGIES,
LLC, a Delaware Limited Liability Company;
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oDoes I-X; Roe Corporations I-X,
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Defendants.
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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;
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Case 2:18-cv-00278-JAD-NJK Document 28 Filed 01/24/19 Page 2 of 2
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ATTORNEYS AT LAW
7435 W. AZURE DR., SUITE 110
LAS VEGAS, NEVADA 89130
Tel. (702) 258-1183 ♦ Fax (702) 258-6983
KEMP & KEMP
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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.
.
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DATED this 23rd day of January 2019.
DATED this 23rd day of January 2019.
JACKSON LEWIS P.C.
KEMP & KEMP
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/s/ Joshua A. Sliker, Esq.
Joshua A. Sliker, Esq.
Attorneys for Defendant
/s/ James P. Kemp, Esq.
James P. Kemp, Esq.
Attorneys for Plaintiff
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IT IS SO ORDERED.
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_____________________________________
UNITED STATES MAGISTRATE JUDGE
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DATED:
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January 24, 2019
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