1 }|DENISE A. BRADSHAW, ESQ. Nevada State Bar No.: 10521 2 |IBRADSHAW LAW LLC 603 Pine Street 3 Elko, Nevada 89801 TELE: (775) 738-7444 4 |FACSIMILE: (775) 738-7455 E-Mail: denise@bradshawlawnv.com 5 }HATTORNEY FOR PLAINTIFF 6 |MARK E. TRAFTON, ESQ. Nevada State Bar Number: 6525 7 11900 Industrial Road Las Vegas, Nevada 89102 8 | TELE: (702) 385-1813 FACSIMILE: (702) 382-9633 9 |/E-Mail: mark@belltransportation.com - and - 10 [JOHN H. COTTON, ESQ. Nevada Bar Number 5268 11 |TODD M. WEISS, ESQ. Nevada Bar Number: 14130 12 |JOHN H. COTTON & ASSOCIATES 7900 West Sahara Avenue, Suite 200 13 Las Vegas, Nevada 89117 TELE: (702) 832-5909 14 |FACSIMILE: (702) 832-5910 Email: jncotton@cottonlaw.com 15 tweiss@cottonlaw.com 6 ATTORNEYS FOR DENBEL & WHITTLESEA RHONDA LONG, ESQ. 17 |Nevada Bar Number: 10921 LAW OFFICE OF LEE J. GRANT, II 18 18345 West Sunset Road, Suite 250 Las Vegas, Nevada 89113 19 | TELE: (702) 233-9303 FACSIMILE: (702) 780-8119 20 E-Mail: Rhlong@geico.com ATTORNEY FOR GLENN WILLIAM MURPHY
UNITED STATES DISTRICT COURT
33 DISTRICT OF NEVADA
JOSEPHINE DI VINCENZO, ) CASE NO.: 2:19-cv-01994-JAD-VCF ) Plaintiff, ) 25 ) vs. ) STIPULATION AND ORDER GRANTING 26 ) LEAVE TO PLAINTIFF TO FILE SOLOMON WO4JI DENBEL; ) SECOND AMENDED COMPLAINT 27 |WHITTLESEA BLUE CAB COMPANY, ) AND TO AMEND CAPTION 28 Ilcontinued...
1 a Nevada corporation; GLENN ) WILLIAM MURPHY; DOES I-X, ) 2 inclusive; ABC CORPORATIONS, ) inclusive; and, XYZ PARTNERSHIPS, ) 3 inclusive, ) ) 4 Defendants. ) ________________________________) 5 6 IT IS HEREBY STIPULATED, by and among counsel for the parties, pursuant to LR 7 26-1(b)(2), that Plaintiff may file her Second Amended Complaint (a copy of which is 8 attached hereto as Exhibit “A”) in the above-entitled action. 9 IT IS FURTHER STIPULATED that, pursuant to Graziose v. Am. Home Prods. Corp., 10 .... 11 .... 12 .... 13 .... 14 .... 15 .... 16 .... 17 .... 18 .... 19 .... 20 .... 21 .... 22 .... 23 .... 24 .... 25 .... 26 .... 27 .... 28 .... 1 202 F.R.D. 638, 643 (D. Nev. 2001), the DOE allegations be removed from the caption. 2 DATED this 6" __ day of MAY, 2020. 3 |BRADSHAW LAW LLC 5 |By: /s/ DENISE A. BRADSHAW By: /s/ MARK E. TRAFTON DENISE A. BRADSHAW MARK E. TRAFTON 6 Nevada Bar Number: 10521 Nevada Bar Number: 6525 603 Pine Street 1900 Industrial Road 7 Elko, Nevada 89801 Las Vegas, Nevada 89102 ATTORNEY FOR PLAINTIFF ATTORNEY FOR DENBEL/ 8 WHITTLESEA BLUE CAB COMPANY 9 |LAW OFFICE OF LEE J. GRANT, Il JOHN H. COTTON & ASSOCIATES 10 11 |By: /s/ RHONDA LONG By: /s/ JOHN H. COTTON RHONDA LONG JOHN H. COTTON 12 Nevada Bar Number: 10921 Nevada Bar Number: 5268 8345 West Sunset Road, Suite 250 TODD M. WEISS 13 Las Vegas, Nevada 89113 Nevada Bar Number: 14130 ATTORNEY FOR GLENN WILLIAM 7900 West Sahara Avenue, #200 14 MURPHY Las Vegas, Nevada 89117 ATTORNEYS FOR DENBEL/ 15 WHITTLESEA BLUE CAB COMPANY 16 17 ORDER 18 IT IS SO ORDERED. 19 IT IS FURTHER ORDERED that the caption in the above-entitled action shall be 20 |)... 21}... 22 |... IT 15 SO ORDERED. 24 |... fa OME EES
25 UNITED STATES MAGISTRATE JUDGE 26 DATED: 5-15-2020 0 27 enon 28 enon -3-
EXHIBIT “A”
1 [DENISE A. BRADSHAW, ESQ. Nevada State Bar No.: 10521 2 |BRADSHAW LAW LLC 603 Pine Street 3 ||Elko, Nevada 89801 TELE: (775) 738-7444 4 FACSIMILE: (775) 738-7455 ; E-Mail: denise@bradshawlawnv.com ‘ ATTORNEY FOR PLAINTIFF
7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 | JOSEPHINE DI VINCENZO, ) CASE NO.: 2:19-cv-01994-JAD-VCF ) 10 Plaintiff, 11 |lvs. ) SECOND AMENDED COMPLAINT ) 12 |SOLOMON WOJI DENBEL; ) WHITTLESEA BLUE CAB COMPANY, ) 13 lla Nevada corporation; and, GLENN ) 4 WILLIAM MURPHY, ) ) Defendants. ) 15 ) 16 Plaintiff, JOSEPHINE DI VINCENZO, by and through her counsel, DENISE A. 17 BRADSHAW, ESQ. of BRADSHAW LLC, for her Second Amended Complaint against 18 IIthe Defendants, and each of them, avers and alleges as follows: 19 JURISDICTION 20 I. 21 Pursuant to LR 8-1, this case was removed from the Eighth Judicial District Court of 22 |lthe State of Nevada to the United State District Court on November 15, 2019, pursuant to 23 1128 U.S.C. §§ 1332, 1441 and 1446 and has since proceeded in this Court. 24 25 That Plaintiff, JOSEPHINE DI VINCENZO, is a resident of Canada. 26 Ul. 27 That at all times pertinent hereto, Defendant, SOLOMON WO4J! DENBEL, was □ 28 ilresident of County of Clark, State of Nevada, and acting as a common motor carrier of
1 ||passengers in his capacity as an employee, agent and/or representative of Defendant 2 |WHITTLESEA BLUE CAB COMPANY. 3 IV. 4 That at all times pertinent hereto, Defendant, WHITTLESEA BLUE CAB COMPANY 5 ||was a corporation formed by virtue of and doing business in and under the laws of the State 6 lof Nevada as a common motor carrier of passengers. 7 Vv. 8 That at all times pertinent hereto, Defendant, GLENN WILLIAM MURPHY, was é 9 |lresident of the County of Clark, State of Nevada. 10 FIRST CLAIM FOR RELIEF 1] (Negligence) 12 Vi. 13 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, was ar 14 employee, agent and/or representative of Defendant, WHITTLESEA BLUE CAE 15 |ICOMPANY, acting under the direction and control of Defendant, WHITTLESEA BLUE CAE 16 |COMPANY, and was within the course and scope of his employment and/or agency 17 jlostensible or otherwise, with Defendants, and each of them. His actions as alleged hereir 18 |lwere either expressly or impliedly ratified and approved by Defendants, and each of them 19 Vil. 20 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, wa: 21 lloperating a 2016 Ford Transit Connect Van Taxicab which was owned by Defendant 22 IWHITTLESEA BLUE CAB COMPANY. 23 Vill. 24 That at all times pertinent hereto, Defendant, GLENN WILLIAM MURPHY, wa: 25 lloperating a 2006 Ford F150 Pick-Up Truck. 26 IX. 27 That at all times pertinent hereto, Defendants, SOLOMON WOJI DENBEL anc 28 |IGLENN WILLIAM MURPHY, had a duty to operate their respective motor vehicles in a safe
1 lawful and reasonable manner on the public roadways in the State of Nevada. 2 Xx. 3 That on or about the 7" day of OCTOBER, 2017, Plaintiff, JOSEPHINE DI 4 IVINCENZO, lawfully entrusted Defendants, and each of them, with her safety and well- 5 being by entering the 2016 Ford Transit Connect Van Taxicab as a guest and business 6 llinvitee. That Plaintiff provided Defendant, SOLOMON WOJI DENBEL, with the address of 7 \her intended destination. 8 Xl. 9 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, owed a 10 heightened duty of care to Plaintiff - his passenger in the 2016 Ford Transit Connect Van 11 |Taxicab. 12 □□□ 13 That at the time aforesaid, Defendant, SOLOMON WOJI DENBEL, with Plaintiff as 14 |lhis passenger, was operating the 2016 Ford Transit Connect Van Taxicab westbound on 15 |Spring Mountain at the intersection with Interstate 15 in the County of Clark, State □□ 16 Nevada. 17 Xill. 18 That at the time and place aforesaid, Defendant, GLENN WILLIAM MURPHY, was 19 operating the 2006 Ford F150 Pick-Up Truck eastbound on Spring Mountain approaching 20 |Ithe Interstate 15 intersection. 21 XIV. 22 That at the time and place aforesaid, Defendants, and each of them, so recklessly 23 icarelessly, negligently and in violation of state laws and local ordinances, operated theil 24 respective motor vehicles as to cause them to collide. 25 XV. 26 That as direct and proximate result of the recklessness, carelessness, negligence 27 land negligence per se of the Defendants, and each of them, Plaintiff suffered serious 28 llnersonal injuries and pain and suffering all to her general damage in a just and reasonable
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1 }|DENISE A. BRADSHAW, ESQ. Nevada State Bar No.: 10521 2 |IBRADSHAW LAW LLC 603 Pine Street 3 Elko, Nevada 89801 TELE: (775) 738-7444 4 |FACSIMILE: (775) 738-7455 E-Mail: denise@bradshawlawnv.com 5 }HATTORNEY FOR PLAINTIFF 6 |MARK E. TRAFTON, ESQ. Nevada State Bar Number: 6525 7 11900 Industrial Road Las Vegas, Nevada 89102 8 | TELE: (702) 385-1813 FACSIMILE: (702) 382-9633 9 |/E-Mail: mark@belltransportation.com - and - 10 [JOHN H. COTTON, ESQ. Nevada Bar Number 5268 11 |TODD M. WEISS, ESQ. Nevada Bar Number: 14130 12 |JOHN H. COTTON & ASSOCIATES 7900 West Sahara Avenue, Suite 200 13 Las Vegas, Nevada 89117 TELE: (702) 832-5909 14 |FACSIMILE: (702) 832-5910 Email: jncotton@cottonlaw.com 15 tweiss@cottonlaw.com 6 ATTORNEYS FOR DENBEL & WHITTLESEA RHONDA LONG, ESQ. 17 |Nevada Bar Number: 10921 LAW OFFICE OF LEE J. GRANT, II 18 18345 West Sunset Road, Suite 250 Las Vegas, Nevada 89113 19 | TELE: (702) 233-9303 FACSIMILE: (702) 780-8119 20 E-Mail: Rhlong@geico.com ATTORNEY FOR GLENN WILLIAM MURPHY
UNITED STATES DISTRICT COURT
33 DISTRICT OF NEVADA
JOSEPHINE DI VINCENZO, ) CASE NO.: 2:19-cv-01994-JAD-VCF ) Plaintiff, ) 25 ) vs. ) STIPULATION AND ORDER GRANTING 26 ) LEAVE TO PLAINTIFF TO FILE SOLOMON WO4JI DENBEL; ) SECOND AMENDED COMPLAINT 27 |WHITTLESEA BLUE CAB COMPANY, ) AND TO AMEND CAPTION 28 Ilcontinued...
1 a Nevada corporation; GLENN ) WILLIAM MURPHY; DOES I-X, ) 2 inclusive; ABC CORPORATIONS, ) inclusive; and, XYZ PARTNERSHIPS, ) 3 inclusive, ) ) 4 Defendants. ) ________________________________) 5 6 IT IS HEREBY STIPULATED, by and among counsel for the parties, pursuant to LR 7 26-1(b)(2), that Plaintiff may file her Second Amended Complaint (a copy of which is 8 attached hereto as Exhibit “A”) in the above-entitled action. 9 IT IS FURTHER STIPULATED that, pursuant to Graziose v. Am. Home Prods. Corp., 10 .... 11 .... 12 .... 13 .... 14 .... 15 .... 16 .... 17 .... 18 .... 19 .... 20 .... 21 .... 22 .... 23 .... 24 .... 25 .... 26 .... 27 .... 28 .... 1 202 F.R.D. 638, 643 (D. Nev. 2001), the DOE allegations be removed from the caption. 2 DATED this 6" __ day of MAY, 2020. 3 |BRADSHAW LAW LLC 5 |By: /s/ DENISE A. BRADSHAW By: /s/ MARK E. TRAFTON DENISE A. BRADSHAW MARK E. TRAFTON 6 Nevada Bar Number: 10521 Nevada Bar Number: 6525 603 Pine Street 1900 Industrial Road 7 Elko, Nevada 89801 Las Vegas, Nevada 89102 ATTORNEY FOR PLAINTIFF ATTORNEY FOR DENBEL/ 8 WHITTLESEA BLUE CAB COMPANY 9 |LAW OFFICE OF LEE J. GRANT, Il JOHN H. COTTON & ASSOCIATES 10 11 |By: /s/ RHONDA LONG By: /s/ JOHN H. COTTON RHONDA LONG JOHN H. COTTON 12 Nevada Bar Number: 10921 Nevada Bar Number: 5268 8345 West Sunset Road, Suite 250 TODD M. WEISS 13 Las Vegas, Nevada 89113 Nevada Bar Number: 14130 ATTORNEY FOR GLENN WILLIAM 7900 West Sahara Avenue, #200 14 MURPHY Las Vegas, Nevada 89117 ATTORNEYS FOR DENBEL/ 15 WHITTLESEA BLUE CAB COMPANY 16 17 ORDER 18 IT IS SO ORDERED. 19 IT IS FURTHER ORDERED that the caption in the above-entitled action shall be 20 |)... 21}... 22 |... IT 15 SO ORDERED. 24 |... fa OME EES
25 UNITED STATES MAGISTRATE JUDGE 26 DATED: 5-15-2020 0 27 enon 28 enon -3-
EXHIBIT “A”
1 [DENISE A. BRADSHAW, ESQ. Nevada State Bar No.: 10521 2 |BRADSHAW LAW LLC 603 Pine Street 3 ||Elko, Nevada 89801 TELE: (775) 738-7444 4 FACSIMILE: (775) 738-7455 ; E-Mail: denise@bradshawlawnv.com ‘ ATTORNEY FOR PLAINTIFF
7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 | JOSEPHINE DI VINCENZO, ) CASE NO.: 2:19-cv-01994-JAD-VCF ) 10 Plaintiff, 11 |lvs. ) SECOND AMENDED COMPLAINT ) 12 |SOLOMON WOJI DENBEL; ) WHITTLESEA BLUE CAB COMPANY, ) 13 lla Nevada corporation; and, GLENN ) 4 WILLIAM MURPHY, ) ) Defendants. ) 15 ) 16 Plaintiff, JOSEPHINE DI VINCENZO, by and through her counsel, DENISE A. 17 BRADSHAW, ESQ. of BRADSHAW LLC, for her Second Amended Complaint against 18 IIthe Defendants, and each of them, avers and alleges as follows: 19 JURISDICTION 20 I. 21 Pursuant to LR 8-1, this case was removed from the Eighth Judicial District Court of 22 |lthe State of Nevada to the United State District Court on November 15, 2019, pursuant to 23 1128 U.S.C. §§ 1332, 1441 and 1446 and has since proceeded in this Court. 24 25 That Plaintiff, JOSEPHINE DI VINCENZO, is a resident of Canada. 26 Ul. 27 That at all times pertinent hereto, Defendant, SOLOMON WO4J! DENBEL, was □ 28 ilresident of County of Clark, State of Nevada, and acting as a common motor carrier of
1 ||passengers in his capacity as an employee, agent and/or representative of Defendant 2 |WHITTLESEA BLUE CAB COMPANY. 3 IV. 4 That at all times pertinent hereto, Defendant, WHITTLESEA BLUE CAB COMPANY 5 ||was a corporation formed by virtue of and doing business in and under the laws of the State 6 lof Nevada as a common motor carrier of passengers. 7 Vv. 8 That at all times pertinent hereto, Defendant, GLENN WILLIAM MURPHY, was é 9 |lresident of the County of Clark, State of Nevada. 10 FIRST CLAIM FOR RELIEF 1] (Negligence) 12 Vi. 13 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, was ar 14 employee, agent and/or representative of Defendant, WHITTLESEA BLUE CAE 15 |ICOMPANY, acting under the direction and control of Defendant, WHITTLESEA BLUE CAE 16 |COMPANY, and was within the course and scope of his employment and/or agency 17 jlostensible or otherwise, with Defendants, and each of them. His actions as alleged hereir 18 |lwere either expressly or impliedly ratified and approved by Defendants, and each of them 19 Vil. 20 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, wa: 21 lloperating a 2016 Ford Transit Connect Van Taxicab which was owned by Defendant 22 IWHITTLESEA BLUE CAB COMPANY. 23 Vill. 24 That at all times pertinent hereto, Defendant, GLENN WILLIAM MURPHY, wa: 25 lloperating a 2006 Ford F150 Pick-Up Truck. 26 IX. 27 That at all times pertinent hereto, Defendants, SOLOMON WOJI DENBEL anc 28 |IGLENN WILLIAM MURPHY, had a duty to operate their respective motor vehicles in a safe
1 lawful and reasonable manner on the public roadways in the State of Nevada. 2 Xx. 3 That on or about the 7" day of OCTOBER, 2017, Plaintiff, JOSEPHINE DI 4 IVINCENZO, lawfully entrusted Defendants, and each of them, with her safety and well- 5 being by entering the 2016 Ford Transit Connect Van Taxicab as a guest and business 6 llinvitee. That Plaintiff provided Defendant, SOLOMON WOJI DENBEL, with the address of 7 \her intended destination. 8 Xl. 9 That at all times pertinent hereto, Defendant, SOLOMON WOJI DENBEL, owed a 10 heightened duty of care to Plaintiff - his passenger in the 2016 Ford Transit Connect Van 11 |Taxicab. 12 □□□ 13 That at the time aforesaid, Defendant, SOLOMON WOJI DENBEL, with Plaintiff as 14 |lhis passenger, was operating the 2016 Ford Transit Connect Van Taxicab westbound on 15 |Spring Mountain at the intersection with Interstate 15 in the County of Clark, State □□ 16 Nevada. 17 Xill. 18 That at the time and place aforesaid, Defendant, GLENN WILLIAM MURPHY, was 19 operating the 2006 Ford F150 Pick-Up Truck eastbound on Spring Mountain approaching 20 |Ithe Interstate 15 intersection. 21 XIV. 22 That at the time and place aforesaid, Defendants, and each of them, so recklessly 23 icarelessly, negligently and in violation of state laws and local ordinances, operated theil 24 respective motor vehicles as to cause them to collide. 25 XV. 26 That as direct and proximate result of the recklessness, carelessness, negligence 27 land negligence per se of the Defendants, and each of them, Plaintiff suffered serious 28 llnersonal injuries and pain and suffering all to her general damage in a just and reasonable
1 amount in excess of FIFTEEN THOUSAND DOLLARS AND 00/100 ($15,000.00). 2 XVI. 3 That as a further direct and proximate result of the recklessness, carelessness 4 |Inegligence and negligence per se of the Defendants, and each of them, Plaintiff will incur 5 medical, physician, therapeutic, cognitive and other related expenses into the future in ar 6 amount presently unascertained. Plaintiff prays leave to prove such amounts at the trial o1 7 |Ithis matter. 8 XVII. 9 That as a direct and proximate result of the recklessness, carelessness, negligence 10 land negligence per se of the Defendants, and each of them, Plaintiff was required to retair 11 |Ithe services of an attorney to prosecute this matter and is entitled to a reasonable □□□□□□□□□□ 12 fee and costs of suit. 13 WHEREFORE, Plaintiff prays judgment against the Defendants, and each of them 14 llas more fully set forth below. 15 SECOND CLAIM FOR RELIEF 16 (Negligent Entrustment) 17 XVIII. 18 Plaintiff hereby incorporates Paragraphs I-XVII of the Jurisdiction and First Claim fo! 19 |lRelief as though set forth in haec verba. 20 XIX. 21 That Defendant, WHITTLESEA BLUE CAB COMPANY, as a common carrier o 22 llpassengers, owed a duty to Plaintiff to ensure that the operation of its 2016 Ford Transi 23 Connect Van Taxicab on the public roadways in the State of Nevada was performed in ¢ 24 \safe, lawful and reasonable manner. 25 XX. 26 That Defendant, WHITTLESEA BLUE CAB COMPANY, breached its duty to Plaintif 27 by knowingly entrusting said 2016 Ford Transit Connect Van Taxicab to Defendant 28 SOLOMON WOW! DENBEL.
1 XXI. 2 That as a direct and proximate result of the breach of said duty by Defendants, and 3 leach of them, Plaintiff sustained injuries and damages as set forth above. 4 WHEREFORE, Plaintiff prays judgment against the Defendants, and each of them, 5 jlas more fully set forth below. 6 THIRD CLAIM FOR RELIEF 7 (Negligent Supervision/Training) 8 XXIil. 9 Plaintiff hereby incorporates Paragraphs I-XVII of the Jurisdiction and First Claim for 10 Relief and Paragraphs XVIII - XXI of the Second Claim for Relief as though set forth in haec 11 |verba. 12 XXiIll. 13 That at all times pertinent hereto, as set forth above, Defendant, SOLOMON WO4JI 14 |DENBEL, was an employee, agent and/or representative of Defendant, WHITTLESEA 15 [BLUE CAB COMPANY. 16 XIV. 17 That Defendant, WHITTLESEA BLUE CAB COMPANY, as a common carrier of 18 llpassengers, had a heightened duty to protect its passengers by ensuring that its 19 employees, agents and/or representatives operated its vehicles in a safe, lawful anc 20 reasonable manner on the public roadways in the State of Nevada. 21 XXV. 22 That Defendant, WHITTLESEA BLUE CAB COMPANY, a common carrier o 23 lipassengers, had a duty to exercise reasonable care in the selection, training and/o 24 Ilsupervision of its employees, agents and/or representatives who operate its vehicles on the 25 |lpublic roadways so as not to create an unreasonable risk of bodily injury to members of the 26 llpublic, including its guests and business invitees. 27 XXVI. 28 That Defendant, WHITTLESEA BLUE CAB COMPANY, breached said duty tc
1 Plaintiff. 2 XXVII. 2 That as a direct and proximate result of the breach of duty by Defendant. 4 |WHITTLESEA BLUE CAB COMPANY, Plaintiff sustained injuries and damages as set forth 5 llabove. 6 WHEREFORE, Plaintiff, while expressly reserving her right to amend this Complaint 7 to and including the time of trial to include additional Defendants, all theories of recovery 8 and items of damages not yet ascertained, demands judgment against the Defendants, anc 9 leach of them, as follows: 10 1. For general damages for in a just and reasonable amount in excess of FIFTEEN 11 |} THOUSAND DOLLARS AND 00/100 ($15,000.00); 12 2. For special damages for future medical, therapeutic, cognitive and relatec 13 expenses to be proven at the trial of this matter; 14 3. For reasonable attorney's fees and costs incurred herein; 15 4. For prejudgment interest according to law; and, 16 5. For such other and further relief as the Court may deem just and proper in the 17 premises. 18 DATED this (pth day of MAY, 2020. 19 BRADSHAW+AW LLC □□ (AWEGAMY” 21 BY: WMA 22 occu 23 Fiko, Nevada 39801 ATTORNEY FOR PLAINTIFF 26 27 28
1 CERTIFICATE OF SERVICE BY MAIL 2 | hereby certify that | am an employee of BRADSHAW LAW LLC, and that on this 3 |Idate, pursuant to FRCP 5(b), | deposited in the United States mail at Elko, Nevada, a 4 |Iltrue and correct copy of the foregoing document addressed to: 5 MARK E. TRAFTON, ESQ. 1900 Industrial Road 6 Las Vegas, Nevada 89102; 7 JOHN H. COTTON, ESQ. TODD M. WEISS, ESQ. 8 JOHN H. COTTON & ASSOCIATES, LTD. 7900 West Sahara Avenue, Suite 20 9 Las Vegas, Nevada 89117; and, 10 RHONDA LONG, ESQ. LAW OFFICES OF LEE J. GRANT, Il 11 8345 West Sunset Road, Suite 250 Las Vegas, Nevada 89113.
13 DATED this day of MAY, 2020. 14 15 LISA M. FARMER 16 17 18 19 20 21 22 23 24 25 26 27 28