Board of Trustees of the Glaziers Joint Trust Funds et al v. M-Core Construction, LLC et al

Filing 6

ORDER Granting 5 Stipulation to Extend Deadline for Service of Process. Proof of service deadline: 8/16/2018. Signed by Magistrate Judge Carl W. Hoffman on 7/2/2018. (Copies have been distributed pursuant to the NEF - SLD)

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CHRISTENSEN JAMES & MARTIN, CHTD.
Kevin B. Christensen, Esq. (175)
Wesley J. Smith, Esq. (11871)
Kevin B. Archibald, Esq. (13817)
7440 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
[e-mail], [e-mail], [e-mail]
Attorneys for Plaintiffs Board of Trustees
of the Glaziers Joint Trust Funds, et al.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

CHRISTENSEN JAMES & MARTIN, CHTD.

7440 WEST SAHARA AVE., LAS VEGAS, NEVADA 89117
PH: [phone] § FAX: [phone]

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*****
BOARD OF TRUSTEES OF THE
GLAZIERS JOINT TRUST FUNDS;
INTERNATIONAL UNION OF
PAINTERS AND ALLIED TRADES,
DISTRICT COUNCIL 15, GLAZIERS,
ARCHITECTURAL METAL AND
GLASSWORKERS’ LOCAL UNION
2001

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CASE NO.: 2:18-cv-00598-JCM-CWH
STIPULATION AND ORDER
TO EXTEND DEADLINE FOR
SERVICE OF PROCESS

Plaintiffs,

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vs.

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M-CORE CONSTRUCTION, LLC, A
New Mexico limited liability company;
MGM GRAND HOTEL LLC dba MGM
GRAND HOTEL AND CASINO, a
Nevada limited liability company; MGM
RESORTS INTERNATIONAL dba
MGM RESORTS INTERNATIONAL
DESIGN, a Delaware corporation; MGP
LESSOR, LLC, a Delaware limited
liability company; JOHN DOES I-XX,
inclusive; and ROE ENTITIES I-XX,
inclusive,

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Date: N/A
Time: N/A

Defendants.
Plaintiffs Board of Trustees of the Glaziers Joint Trust Funds (“Trusts”) and

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International Union of Painters and Allied Trades, District Council 15, Glaziers,
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Architectural Metal and Glassworkers’ Local Union 2001 (“Union”) (Trusts and Union
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collectively the “Plaintiffs”), by and through their counsel, Christensen James & Martin,

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Chtd., and Defendant M-Core Construction, LLC (“M-Core”), by and through its
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counsel, Kamer Zucker Abbott, hereby stipulate and agree as follows:
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1.

Plaintiffs and M-Core have reached settlement terms that will fully resolve

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CHRISTENSEN JAMES & MARTIN, CHTD.

7440 WEST SAHARA AVE., LAS VEGAS, NEVADA 89117
PH: [phone] § FAX: [phone]

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all issues in this Case, including the claims asserted by the Plaintiffs against the other
Defendants (MGM Grand Hotel LLC dba MGM Grand Hotel and Casino; MGM Resorts
International dba MGM Resorts International Design; and MGP Lessor, LLC). The
Parties are currently working on settlement documents which they believe will be
completed and executed within the next thirty days.
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The settlement documents will require performance of certain actions on

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or before August 11, 2018. Upon completion of those actions, the Parties intend that the

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entire case be dismissed with prejudice.

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3.

The deadline for submitting proof of service of process is July 2, 2018.

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4.

Given the settlement and the time needed to complete the actions required

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thereunder, the Parties stipulate and respectfully request that the deadline for submitting

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proof of service of process be extended by forty-five days to August 16, 2018.

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DATED this 28th day of June, 2018.
KAMER ZUCKER ABBOTT

CHRISTENSEN JAMES & MARTIN

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By: /s/ R. Todd Creer
R. Todd Creer, Esq.
Nevada Bar No. 10016
Email: [e-mail]
Attorneys for M-Core Construction, LLC

By:
/s/ Wesley J. Smith
Wesley J. Smith, Esq.
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Nevada Bar No. 11871
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Attorneys for Plaintiffs Board of
23 Trustees of the of the Glaziers Joint
Trust Funds, et al.
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IT IS SO ORDERED.
UNITED STATES MAGISTRATE JUDGE

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Date:

-2-

July 2, 2018

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CERTIFICATE OF SERVICE

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I am an employee of Christensen James & Martin. On the date of filing the
3 foregoing papers with the Clerk of Court, I caused a true and correct copy to be served in
the following manner:
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☒
ELECTRONIC SERVICE: Pursuant to Local Rule LR IC 4-1 of the United
States District Court for the District of Nevada, the above-referenced document was
6 electronically filed and served on all appearing parties through the Notice of Electronic
Filing automatically generated by the Court.
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☐
UNITED STATES MAIL: By depositing a true and correct copy of the abovereferenced document into the United States Mail with prepaid first-class postage,
9 addressed to the parties at their last-known mailing address(es):
CHRISTENSEN JAMES & MARTIN, CHTD.

7440 WEST SAHARA AVE., LAS VEGAS, NEVADA 89117
PH: [phone] § FAX: [phone]

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☐
OVERNIGHT COURIER: By depositing a true and correct copy of the above11 referenced document for overnight delivery via a nationally-recognized courier,
addressed to the parties listed below which was incorporated by reference and made final
12 in the w at their last-known mailing address.
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☐
ELECTRONIC MAIL:
By sending the above-referenced document via
electronic mail to those persons and those addresses listed below:

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CHRISTENSEN JAMES & MARTIN

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By:

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/s/ Natalie Saville