Filed: Aug. 19, 2019
Latest Update: Aug. 19, 2019
Summary: STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF RELATED CRIMINAL MATTER (Second Request) NANCY J. KOPPE , Magistrate Judge . Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Plaintiff Karen Lasmarias ("Plaintiff"), by and through her undersigned counsel; Defendant Hellene Lopez ("Lopez"), by and through his undersigned counsel; and Defendant University Medical Center of Southern Nevada d/b/a University Medical Center ("UMC"), by and through its undersigned counsel; here
Summary: STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF RELATED CRIMINAL MATTER (Second Request) NANCY J. KOPPE , Magistrate Judge . Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Plaintiff Karen Lasmarias ("Plaintiff"), by and through her undersigned counsel; Defendant Hellene Lopez ("Lopez"), by and through his undersigned counsel; and Defendant University Medical Center of Southern Nevada d/b/a University Medical Center ("UMC"), by and through its undersigned counsel; hereb..
More
STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF RELATED CRIMINAL MATTER
(Second Request)
NANCY J. KOPPE, Magistrate Judge.
Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Plaintiff Karen Lasmarias ("Plaintiff"), by and through her undersigned counsel; Defendant Hellene Lopez ("Lopez"), by and through his undersigned counsel; and Defendant University Medical Center of Southern Nevada d/b/a University Medical Center ("UMC"), by and through its undersigned counsel; hereby stipulate and agree, and respectfully request that the Court stay all discovery in this action pending the resolution of an ongoing criminal matter arising from the same and/or related allegations to those set forth in Plaintiff's Complaint in this action. Due to the pendency of the criminal matter in which Lopez is a Defendant, the parties anticipate that Defendant Lopez would be limited in his ability to substantively participate in discovery in this action without either implicating or otherwise being compelled to waive his Fifth Amendment rights.
On February 24, 2019, the parties submitted a first request to stay discovery in this matter pending resolution Lopez' ongoing criminal matter. See Stipulation and Order to Stay Discovery Pending Resolution of Related Criminal Matter (First Request) [ECF No. 24]. The Court subsequently approved the stipulation and ordered the stay. See Order [ECF No. 24].
On August 15, 2019, Lopez' ongoing criminal matter was continued to September 26, 2019. Accordingly, the parties stipulate and agree, and respectfully request that the Court stay all discovery in this action for an additional three (3) months pending resolution of the ongoing criminal matter. In the event the criminal matter is resolved prior to the expiration of the stay, the parties stipulate and agree to promptly notify this Court of said resolution so that the stay can be lifted and discovery may commence unhindered in this action. In the event the criminal matter is not resolved within the requested stay period of three (3) months, the parties stipulate and agree to coordinate in good faith to request from this Court any further relief as may be necessary to avoid conflict with the ongoing criminal matter, including but not limited to, a request to extend the stay.
DATED this 19th day of August, 2019 DATED this 19th day of August, 2019
MULLINS & TRENCHAK, ATTORNEYS HOLLEY DRIGGS WALCH
AT LAW FINE PUZEY STEIN & THOMPSON
/s/ Philip J. Trenchak /s/ Sean E. Story
PHILIP J. TRENCHAK, ESQ. F. THOMAS EDWARDS, ESQ.
Nevada Bar No. 9924 Nevada Bar No. 9549
VICTORIA C. MULLINS, ESQ. JOHN J. SAVAGE, ESQ.
Nevada Bar No. 13546 Nevada Bar No. 11455
1212 S. Casino Center Blvd. SEAN E. STORY, ESQ.
Las Vegas, Nevada 89104 Nevada Bar No. 13968
400 South Fourth Street, Suite 300
HKM EMPLOYMENT ATTORNEYS LLP Las Vegas, Nevada 89101
JENNY L. FOLEY, ESQ. Attorneys for Defendant University
Nevada Bar No. 9017 Medical Center of Southern Nevada
1785 East Sahara Ave., Suite 325
Las Vegas, Nevada 89104
Telephone: 202-370-8104
Attorneys for Plaintiff Karen Lasmarias
DATED this 19th day of August, 2019
LEAVITT LEGAL GROUP, P.C.
/s/ Kristofer D. Leavitt
KRISTOFER D. LEAVITT, ESQ.
Nevada Bar No. 13173
612 S. 10th Street
Las Vegas, Nevada 89101
Attorneys for Defendant Hellene Lopez
IT IS SO ORDERED.
