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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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: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Ramparts, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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BRYANT LECHUGA,
Plaintiff,

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STIPULATION AND ORDER FOR
DISMISSAL OF CASE WITH
PREJUDICE

vs.

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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.

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Plaintiff BRYANT LECHUGA, and Defendant RAMPARTS, LLC d/b/a Luxor Hotel &

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Casino, by and through their respective counsel of record, hereby stipulate and agree to dismiss this

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case and all claims and allegations therein with prejudice, each party to bear their own fees and

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costs, in accordance with the following which shall constitute binding admissions upon Plaintiff:

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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”).

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JACKSON LEWIS P.C
LAS VEGAS

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4.

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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.
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Except as otherwise alleged in the Charge or Litigation, as those terms are defined

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in the Agreement, Defendant’s decisions regarding the terms and conditions of Plaintiff’s

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employment with Defendant up to and including the Separation Date were not discriminatory or

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harassing based on age, race, color, sex, religion, national origin, disability or any other classification

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protected by law, or retaliatory based on any protected activity.
6.

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he was entitled under the Family and Medical Leave Act or related federal, state or local leave or
disability accommodation laws.
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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.
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Plaintiff has not divulged any proprietary or confidential information of Defendant

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and will continue to maintain the confidentiality of such information consistent with Defendant’s

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policies and Plaintiff’s agreement(s) with Defendant and/or common law.
9.

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Except as otherwise alleged in the Charge or Litigation, as those terms are defined

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in the Agreement, Plaintiff has not been retaliated against for reporting any allegations of

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wrongdoing by Defendant or its officers, including any allegations of corporate fraud.
10.

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Plaintiff has not been subjected to any act, omission, conduct or injury, since the

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date he signed the Agreement, which would give rise to a claim or cause of action against Defendant.

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JACKSON LEWIS P.C
LAS VEGAS

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11.

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No Released Claims, as that term is defined in the Agreement, have arisen since

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Plaintiff signed the Agreement on April 13, 2021 and the date that this Stipulation is filed with the

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Court.
Dated this 28th day of April, 2021.

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KEMP & KEMP

JACKSON LEWIS P.C.

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/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

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ORDER

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IT IS SO ORDERED.

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United States District Judge

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Dated: April 28, 2021
Case No. 2:19-cv-01731-APG-BNW

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4825-5634-5063, v. 1

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JACKSON LEWIS P.C
LAS VEGAS

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