Lechuga v. Ramparts, LLC

Filing 53

ORDER Granting 52 Stipulation of Dismissal With Prejudice. Signed by Judge Andrew P. Gordon on 4/28/2021. (Copies have been distributed pursuant to the NEF - JQC)

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1 2 3 4 5 6 7 8 DEVERIE J. CHRISTENSEN, ESQ. Nevada Bar No. 6596 JOSHUA A. SLIKER, ESQ. Nevada Bar No. 12493 JACKSON LEWIS P.C. 300 South Fourth Street, Suite 900 Las Vegas, Nevada 89101 Telephone: (702) 921-2460 Facsimile: (702) 921-2461 Email: deverie.christensen@jacksonlewis.com Email: joshua.sliker@jacksonlewis.com Attorneys for Defendant Ramparts, LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 BRYANT LECHUGA, Plaintiff, 12 15 STIPULATION AND ORDER FOR DISMISSAL OF CASE WITH PREJUDICE vs. 13 14 Case No. 2:19-cv-01731-APG-BNW RAMPARTS, LLC, a Nevada Limited Liability Company; DOES I-X; and ROE Business Entities I-X, Defendants. 16 17 Plaintiff BRYANT LECHUGA, and Defendant RAMPARTS, LLC d/b/a Luxor Hotel & 18 Casino, by and through their respective counsel of record, hereby stipulate and agree to dismiss this 19 case and all claims and allegations therein with prejudice, each party to bear their own fees and 20 costs, in accordance with the following which shall constitute binding admissions upon Plaintiff: 21 22 23 24 25 26 1. Plaintiff’s employment with Defendant ended on April 21, 2021 (the “Separation 2. Plaintiff has been paid and received all compensation, wages, bonuses, Date”). commissions, and benefits, if any, due and payable to him from Defendant. 3. Plaintiff has received all consideration due to him under the parties’ Confidential Settlement Agreement And General Release Of All Claims (the “Agreement”). 27 28 JACKSON LEWIS P.C LAS VEGAS 1 4. 1 2 Plaintiff has not filed, caused to be filed, or presently is a party to any claim or action against Defendant, other than the instant case. 5. 3 Except as otherwise alleged in the Charge or Litigation, as those terms are defined 4 in the Agreement, Defendant’s decisions regarding the terms and conditions of Plaintiff’s 5 employment with Defendant up to and including the Separation Date were not discriminatory or 6 harassing based on age, race, color, sex, religion, national origin, disability or any other classification 7 protected by law, or retaliatory based on any protected activity. 6. 8 9 10 he was entitled under the Family and Medical Leave Act or related federal, state or local leave or disability accommodation laws. 7. 11 12 Defendant granted Plaintiff any leave and/or reasonable accommodation to which Plaintiff has no known workplace injuries or occupational diseases that have not already been reported to Defendant. 8. 13 Plaintiff has not divulged any proprietary or confidential information of Defendant 14 and will continue to maintain the confidentiality of such information consistent with Defendant’s 15 policies and Plaintiff’s agreement(s) with Defendant and/or common law. 9. 16 Except as otherwise alleged in the Charge or Litigation, as those terms are defined 17 in the Agreement, Plaintiff has not been retaliated against for reporting any allegations of 18 wrongdoing by Defendant or its officers, including any allegations of corporate fraud. 10. 19 Plaintiff has not been subjected to any act, omission, conduct or injury, since the 20 date he signed the Agreement, which would give rise to a claim or cause of action against Defendant. 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// JACKSON LEWIS P.C LAS VEGAS 2 11. 1 No Released Claims, as that term is defined in the Agreement, have arisen since 2 Plaintiff signed the Agreement on April 13, 2021 and the date that this Stipulation is filed with the 3 Court. Dated this 28th day of April, 2021. 4 5 KEMP & KEMP JACKSON LEWIS P.C. 6 /s/ James P. Kemp James P. Kemp, Bar #6375 7435 West Azure Drive, Suite 110 Las Vegas, Nevada 89130 /s/ Joshua A. Sliker Joshua A. Sliker, Bar #12493 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 Attorneys for Plaintiff Attorneys for Defendant 7 8 9 10 ORDER 11 IT IS SO ORDERED. 12 13 United States District Judge 14 Dated: April 28, 2021 Case No. 2:19-cv-01731-APG-BNW 15 16 4825-5634-5063, v. 1 17 18 19 20 21 22 23 24 25 26 27 28 JACKSON LEWIS P.C LAS VEGAS 3

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