Tang et al v. Wynn Las Vegas, LLC

Filing 38

ORDER granting 36 Stipulation to Stay Case for 90 Days. Signed by Judge Andrew P. Gordon on 9/6/2018. (Copies have been distributed pursuant to the NEF - MMM)

1
2
3
4
5
6
7

KAMER ZUCKER ABBOTT
Gregory J. Kamer
#0270
R. Todd Creer
#10016
Nicole A. Young
#13423
3000 West Charleston Boulevard, Suite 3
Las Vegas, Nevada 89102-1990
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
Wynn Las Vegas, LLC

8
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9
10
11
12
13
14
15
16

QUY NGOC TANG and JOSEPH CESARZ, )
and all persons whose names are set forth in
)
Exhibit A, individually and on behalf of all others )
similarly situated,
)
)
Plaintiffs,
)
)
vs.
)
)
WYNN LAS VEGAS, LLC,
)
)
Defendant.
)
______________________________________ )

Case No. 2:18-cv-00891-APG-GWF
JOINT STIPULATION AND
REQUEST FOR STAY

ORDER

17

The parties, by and through their respective counsel of record, hereby jointly stipulate and

18

request that the Court stay the present matter pending the parties’ current efforts to resolve this

19

matter. In support of this request, the parties state the following:

20

1.

Plaintiff filed his Complaint (ECF No. 1) on May 16, 2018 and served the same on

21

Defendant on June 21, 2018. Defendant filed its Answer to Plaintiffs’ Complaint (ECF No. 26) on

22

July 12, 2018.

23
24

2.

Many of the same parties and counsel are involved in ongoing litigation regarding

Defendant’s tip-pooling policies in another case pending in the U.S. District Court, Case No. 2:13-

KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

Page 1 of 3

1

CV-109-RCJ-CWH.

2
3

3.

The parties and counsel are presently engaged in efforts to reach a resolution that

would resolve both the present matter and other litigation.

4

4.

In view of the parties’ ongoing efforts to resolve this matter and the fact that the

5

present matter is in its early stages, it appears more efficient for the parties to try now to resolve this

6

case without incurring the costs of litigation, including discovery and motion work.

7
8

5.

This stipulation is made in good faith and for the reasons referenced above, and not

for purposes of delay or any other improper purpose.

9

6.

In view of the foregoing, the parties jointly stipulate and request that the present

10

proceeding be stayed for a period of ninety (90) days to facilitate the parties’ continuing efforts to

11

resolve this matter.

12

DATED this 21st day of August, 2018.

13

THIERMAN LAW FIRM

14
15
16
17
18
19

By:

/s/ Mark R. Thierman
Mark R. Thierman
#8285
7287 Lakeside Drive
Reno, Nevada 89511
Tel: [phone]
Leon Greenberg #8094
Leon Greenberg Professional Corp.
2965 South Jones Boulevard, Suite E-3
Las Vegas, Nevada 89146
Tel: [phone]
Fax: [phone]

20
21
22

James P. Kemp
#6375
Kemp & Kemp, Attorneys at Law
7435 West Azure Drive, Suite 110
Las Vegas, Nevada 89130
Tel: [phone]

23
24

Robin Potter
111 East Wacker Drive, Suite 2600
Chicago, Illinois 60601
KAMER ZUCKER ABBOTT

KAMER ZUCKER ABBOTT
By:

/s/ R. Todd Creer
Gregory J. Kamer
#0270
R. Todd Creer
#10016
Nicole A. Young
#13423
3000 W. Charleston Boulevard, Suite 3
Las Vegas, Nevada 89102-1990
Tel: [phone]
Fax: [phone]
Attorneys for Defendant

IT IS SO ORDERED.

_________________________________
UNITED STATES DISTRICT JUDGE
Dated: September 6, 2018.

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

Page 2 of 3