Boggs v. Union Pacific Railroad Company

Filing 17

ORDER granting 16 Stipulation of Dismissal with Prejudice. Case terminated. Signed by Judge James C. Mahan on 3/1/2019. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-00816-JCM-CWH Document 16 Filed 02/27/19 Page 1 of 3

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MURPHY, CAMPBELL, ALLISTON & QUINN

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L. DIPAUL MARRERO II, ESQ.
GOLIGHTLY & VANNAH, PLLC
400 S. Seventh Street, Suite 400
Las Vegas, Nevada 89101
Telephone [phone]
Facsimile [phone]
Attorney for Plaintiff
TATIANA BOGGS
Stephanie L. Quinn
Nevada Bar No. 12632
Murphy, Campbell, Alliston & Quinn
8801 Folsom Blvd, Ste 230
Sacramento, CA 95826
Telephone:
[phone]
E-Mail: [e-mail]
Attorney for Defendant
UNION PACIFIC RAILROAD COMPANY

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TATIANA BOGGS,
Plaintiff,

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vs.

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UNION PACIFIC RAILROAD COMPANY, a
foreign corporation; DOES I through X,
inclusive; and ROE CORPORATIONS I
through X, inclusive,

Case No. 2:18−cv−00816−JCM−CWH
STIPULATED REQUEST FOR
DISMISSAL OF ACTION, WITH
PREJUDICE

Defendants.

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IT IS HEREBY STIPULATED, by and between Plaintiff TATIANA BOGGS, and

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Defendant UNION PACIFIC RAILROAD COMPANY by and through their respective counsel

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of record, that the above-captioned complaint, filed by Plaintiff, be dismissed with prejudice. Each

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party is to bear its own fees and costs.

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///

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///
-1STIPULATED REQUEST FOR DISMISSAL OF ACTION, WITH PREJUDICE AND [PROPOSED]
ORDER

Case 2:18-cv-00816-JCM-CWH Document 16 Filed 02/27/19 Page 2 of 3

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Respectfully submitted,

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DATED: February 27, 2019

GOLIGHTLY & VANNAH, PLLC

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By:
/s/ L. DiPaul Marrero II
L. DIPAUL MARRERO II, ESQ.
Attorneys for Plaintiff

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DATED: February 27, 2019

UNION PACIFIC RAILROAD COMPANY

MURPHY, CAMPBELL, ALLISTON & QUINN

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By:
/s/ Stephanie L. Quinn
Stephanie L. Quinn
Murphy, Campbell, Alliston & Quinn
8801 Folsom Blvd, Ste 230
Sacramento, CA 95826
Attorneys for Defendant
UNION PACIFIC RAILROAD COMPANY

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-2STIPULATED REQUEST FOR DISMISSAL OF ACTION, WITH PREJUDICE AND [PROPOSED]
ORDER

Case 2:18-cv-00816-JCM-CWH Document 16 Filed 02/27/19 Page 3 of 3

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CERTIFICATE OF SERVICE

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Pursuant to NRCP.5(b), I certify that I, Tayler E. Enyart am an employee of Murphy, Campbell,
Alliston & Quinn, and that on February 27, 2019, I served a true and correct copy of the
foregoing document as follows:

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MURPHY, CAMPBELL, ALLISTON & QUINN

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__X___
By electronic serve. The foregoing document was filed electronically with the
United States District Court, District of Nevada. Electronic service will be completed
automatically for all parties who are e-filers and have agreed to accept service in this matter.
The undersigned will confirm that the Notice of Electronic Filing states that the foregoing
document will be electronically mailed; otherwise an alternative method will be used.
By U.S. Mail on all parties in said action, I enclosed the documents in a sealed envelope
or package addressed to the persons at the addresses shown above and placed the envelope for
collection and mailing, following our ordinary business practices. I am readily familiar with this
business’s practice for collecting and processing correspondence for mailing, it is deposited in
the ordinary course of business with the United States Postal Service, in a sealed envelope with
postage fully prepaid. I am employed in the county where the mailing occurred. The envelope
or package was placed in the mail at Sacramento, CA.
Robert D. Vannah, Esq.
L. DiPaul Marrero II, Esq.
GOLIGHTLY & VANNAH, PLLC
400 S. Seventh Street, Suite 400
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff
TATIANA BOGGS

Renee Finch
MESSNER REEVES, LLP
8945 West Russell Road
Suite 300
Las Vegas, NV 89148
[e-mail]

Attorneys for Defendant
UNION PACIFIC RAILROAD
COMPANY

Melissa A. Sandoval
UNION PACIFIC RAILROAD
COMPANY Law Department
10031 Foothills Boulevard, Suite 200
Roseville, CA 95747
Telephone: [phone]
E-Mail: [e-mail]
Mercedes S. Menendez
Office of the Attorney General
Public Safety Division
555 E. Washington Avenue, Suite 3900
Las Vegas, NV 89101
702-486-2625
Fax: [phone]
Email: [e-mail]

Attorneys for Defendant
UNION PACIFIC RAILROAD
COMPANY

Attorneys for Creditor
State of Nevada – Medicaid

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DATED THIS 27th day of February 2019.

/s/ Tayler E Enyart
TAYLER E. ENYART
-3STIPULATED REQUEST FOR DISMISSAL OF ACTION, WITH PREJUDICE AND [PROPOSED]
ORDER

Case 2:18-cv-00816-JCM-CWH Document 16-1 Filed 02/27/19 Page 1 of 1
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MURPHY, CAMPBELL, ALLISTON & QUINN

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L. DIPAUL MARRERO II, ESQ.
GOLIGHTLY & VANNAH, PLLC
400 S. Seventh Street, Suite 400
Las Vegas, Nevada 89101
Telephone [phone]
Facsimile [phone]
Attorney for Plaintiff
TATIANA BOGGS
Stephanie L. Quinn
Nevada Bar No. 12632
Murphy, Campbell, Alliston & Quinn
8801 Folsom Blvd, Ste 230
Sacramento, CA 95826
Telephone:
[phone]
E-Mail: [e-mail]
Attorney for Defendant
UNION PACIFIC RAILROAD COMPANY

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TATIANA BOGGS,

Case No. 2:18−cv−00816−JCM−CWH

Plaintiff,

[PROPOSED] ORDER OF DISMISSAL OF
vs.
ENTIRE ACTION WITH PREJUDICE
PURSUANT TO STIPULATION OF THE
UNION PACIFIC RAILROAD COMPANY, a PARTIES [FRCP 41(a)(1)(A)(ii)]
foreign corporation; DOES I through X,
inclusive; and ROE CORPORATIONS I
through X, inclusive,
Defendants.
Pursuant to the stipulation of the parties hereto, under Federal Rule of Civil Procedure
41(a)(1)(A)(ii), and good cause appearing therefor,

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IT IS HEREBY ORDERED that this action be, and hereby is, dismissed with prejudice as

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to all claims and causes of action, and as to all parties, with each party bearing that parties’ own

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attorneys’ fees and costs.

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March 1, 2019
DATED: _______________

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___________________________________
James C. Mahan
Judge, United States District Court

-1[PROPOSED] ORDER OF DISMISSAL OF ENTIRE ACTION WITH PREJUDICE PURSUANT TO
STIPULATION OF THE PARTIES