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Torres v. Casino

United States District Court, D. Nevada

October 11, 2019

DANIEL TORRES, an individual, Plaintiff,
v.
GOLDEN NUGGET CASINO, et al., Defendants.

          Raymond E. Areshenko Nevada Bar No. 13659 REA Law Attorney for Plaintiff Daniel Torres

          Robert Molina, Esq. Nevada Bar No. 6422 Attorneys for Defendant GNLV, LLC

          STIPULATION TO VACATE ALL DEADLINES AND HEARINGS

         The parties in the above-referenced case, by and through their counsel, submit this Stipulation to Vacate all Deadlines and Hearing Dates. The Parties have filed a Notice of Settlement (docket no. 45). The parties to this action have reached a settlement agreement (“Release”), which has been executed. The only remaining issue to complete the settlement is for Defendant to tender the settlement funds to Plaintiff, which is estimated to take 30 days or less. The parties intend to file a joint request for dismissal as soon as practicable but request 45 days from the date of this Notice to complete the terms of the settlement and file a joint request for dismissal.

         In light of this settlement, and pursuant to Local Rules 7-1 and IA 6-2, the Parties, by and through their respective counsel, stipulate and agree as follows:

         WHEREAS, the Parties have agreed to settle the matter in accordance with the terms set forth in the Release, which has already been executed;

         WHEREAS, there are various deadlines and hearings established by this Court as set forth in the Scheduling Order (docket no. 35) and the Minute Order setting the hearing on Plaintiffs Motion to Extend Time currently set for November 4, 2019 (docket no. 42);

         WHEREAS, the Parties expect such conditions of settlement (payment) to be completed within 30 days of the filing of this Stipulation;

         WHEREAS, the Parties stipulate and respectfully request that the Court vacate all deadlines governing this case and all hearings, including the hearing on Plaintiffs Motion to Extend Time currently set for November 4, 2019, with the understanding that Plaintiffs will file a request for dismissal of the Action following receipt of payment of the settlement funds; in the unlikely event that the settlement conditions are not completed within the time agreed by the Parties, Plaintiff will request a further case management conference to set new case management deadlines.

         NOW THEREFORE, the Parties stipulate and respectfully request that the Court vacate all deadlines and hearings in this case.

         Plaintiff is filing this Stipulation with the Defendant's approval and permission.

         IT IS SO ORDERED.

         IT IS FURTHER ORDERED that the parties are to file a stipulation to dismiss by November 25, 2019. If no such stipulation is filed by this date, the parties are to file a joint status report on November 25, 2019 stating what is impeding the completion of settlement and if or how the court can assist.

         PROOF OF SERVICE

         I am over the age of 18 and not a party to the within action. On October 8, 2019, I served the ...


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