Bachmann v. Whalen et al

Filing 25

ORDER granting 23 Stipulation to Withdraw Motion to Dismiss (ECF No. 8 ); and Stay Discovery. Signed by Magistrate Judge Craig S. Denney on 3/10/2025. (Copies have been distributed pursuant to the NEF - DRM)

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SAGEBRUSH LAW GROUP, PLLC
Astrid A. Perez, Esq. (NSB 15977)
PO Box 13744
Reno, NV 89507
Phone [phone]| Fax [phone]
[e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
PAMELA BACHMANN, an individual,

Case No.: 3:24-cv-00382-CSD

Plaintiff,
ORDER GRANTING
STIPULATION TO WITHDRAW
STATE OF NEVADA DEPARTMENT OF MOTION TO DISMISS AND STAY
TRANSPORTATION, a public entity; JAMES DISCOVERY
vs.

WHALEN, an individual: DOES I through X.
inclusive; and ROE COOPERATIONS I through
X, inclusive,
Defendant.

Plaintiff PAMELA BACHMANN (hereinafter “Plaintiff”), by and through her counsel of

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record Astrid A. Perez, Esq of Sagebrush Law Group, PLLC, and Defendants STATE OF

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NEVADA DEPARTMENT OF TRANSPORTATION, and JAMES WHALEN, (collectively,

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“Defendants”), by and through its counsel of record AARON D. FORD, Attorney General for the
State of Nevada, DANIEL R. HANSEN, Esq. Deputy Attorney General. of the Office of the
Attorney General, hereby stipulate and submit to the Court for consideration the following
STIPULATION TO WITHDRAW MOTION TO DISMISS AND STAY DISCOVERY.
On Thursday, March 6, 2025, the parties attended and participated in good faith the Early
Neutral Evaluation. The parties were unable to reach a resolution, but have agreed to participate
in a continued ENE, scheduled for April 10, 2025, at 9 a.m. In consideration of the continued ENE,
the parties have agreed to withdraw the Motion to Dismiss pending before the Court and maintain
STIPULATION TO WITHDRAW MOTION TO DISMISS AND STAY DISCOVERY - 1

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the stay of discovery. The parties agree that if the matter is not resolved at the continued ENE, the

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parties will refile the withdrawn Motion to Dismiss [ECF 8], Opposition to Motion to Dismiss

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[ECF 10 ], and Reply in Support of Motion to Dismiss [ECF 11]. The Motion to Dismiss will be
filed within 7 days of the continued ENE. The Opposition to the Motion to Dismiss will be filed

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within 4 days of the refiled Motion to Dismiss. The Reply in Support of Motion to Dismiss will

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be filed within 4 days of the days of the refiled Opposition to the Motion to Dismiss. All refiled

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documents will be identical to the originally filed documents.

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The stay of discovery will remain in effect until said decision has been made on the
renewed Motion to Dismiss.

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Dated this 10th day of March, 2025

Dated this 7th day of March, 2025

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/s/ Astrid A. Perez
Astrid A. Perez, Esq. (NSB 15977)
SAGEBRUSH LAW GROUP, PLLC
PO Box 13744
Reno, NV 89507
Phone [phone]| Fax [phone]
[e-mail]

/s/ Daniel R. Hansen
DANIEL R. HANSEN
Nevada Bar No. 14536
Deputy Attorney General
Attorney for Defendants, State of NevadaDepartment of Transportation, James
Whalen, an individual.

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IT IS SO ORDERED:
Dated this 10th
___ of ____________________,
2025.
March

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO WITHDRAW MOTION TO DISMISS AND STAY DISCOVERY - 2