Julieth Mateus Munoz; David Ramirez Torres v. Miroslaw Kleczkowski; Sky Dive Logistics Inc.; Transport Enterprise Leasing, LLC; Allan Caballero Enamorada; Jose Mendoza; Doe Driver I-X; Doe Owner I-X; Roe Employer I-X; Roe Company I-X; Allan I. Caballero Enamorado, an individual; Sonia Y. Caballero Vegas, an individual; and Elin. Caballero Enamorado, an individual; Miguel A. Ochoa, an individual; and Erika Jimenez-Garcia, an individual v. Miroslaw Kleczkowski, an individual; Sky Dive Logistics Inc., a foreign limited-liability company; Does 1 through X; and Roe Corporations I through X, inclusive.

• Court: District Court, D. Nevada
• Decided: January 27, 2026
• Docket: 2:25-cv-01831
• Status: Unknown

Opinion

1 || Daniel R. Price (NV Bar No. 13564) Christopher Beckstrom (NV Bar No. 14031) 2 || Janice J. Parker (NV Bar No. 14102) Krysa Scully (NV Bar No. 16751) 3 || PRICE & BECKSTROM 1404 S. Jones Blvd. 4 || Las Vegas, Nevada 89146 Phone: (702) 941-0503 5 || Fax: (702) 832-4026 info@pbnv.law 6 || Attorneys for Plaintiffs Julieth Mateus Munoz and David Ramirez Torres 7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 8 JULIETH MATEUS MUNOZ; DAVID Case No.: 2:25-cv-01831-RFB-EJY 9 || RAMIREZ TORRES; Plaintiffs, v. 41 MIROSLAW KLECZKOWSKI; SKY DIVE LOGISTICS INC.; TRANSPORT ENTERPRISE Stipulation for Determination of Good 12 || LEASING, LLC; ALLAN CABALLERO Faith Settlement and Dismissal of ENAMORADO; JOSE MENDOZA; DOE Plaintiffs Julieth Mateus Munoz and 13 DRIVER I-X; DOE OWNER I-X; ROE David Ramirez Torres EMPLOYER I-X; ROE COMPANY I-X; 14 Defendants. 15 ALLAN I. CABALLERO ENAMORADO, an 16 individual; SONIA Y. CABALLERO VEGAS, an individual; and ELIN. CABALLERO 17 ENAMORADO, an individual; MIGUEL A. OCHOA, an individual; and ERIKA JIMENEZ- 18 || GARCIA, an individual, 19 Plaintiffs, Vv. 20 || MIROSLAW KLECZKOWSKI, an individual; SKY DIVE LOGISITCS INC., a foreign limited- 21 liability company; DOES 1 through X; and ROE CORPORATIONS I through X, inclusive; 22 Defendants. 23 COME NOW the patties appearing in the above-captioned action, through undersigned 24 counsel of record, and do stipulate as follows:

1 1. This consolidated personal injury action arises from a multi-vehicle motor vehicle collision 2 || occurring on or about May 22, 2023. 3 2. Prior to the removal of this action to federal court, Plaintiffs Julieth Mateus Munoz and 4 || David Ramirez Torres resolved their claims against Defendants Transport Enterprise Leasing LLC, 5 || Allan Caballero Enamorado, and Jose Mendoza. 6 3. As of the date of the instant stipulation, Plaintiffs Julieth Mateus Munoz and David Ramirez 7 || Torres have now settled their claims against Defendants Miroslaw Kleczkowski and Sky Dive 8 || Logistics, Inc.

9 4. The parties stipulate that the proposed settlement is a good faith settlement as defined by 10 |) NRS 17.245. 11 5. In determining whether a settlement was entered in good faith, Nevada courts consider: (1) 12 || the amount paid in settlement; (2) the allocation of settlement proceeds among the plaintiffs; (3) the 13 || policy limits of available insurance and the financial condition of the settling defendant; (4) whether 14 || the settlement was the product of collusion, fraud, or other tortious conduct intended to injure the 15 || interests of non-settling defendants; and (5) whether the settlement is otherwise fair and reasonable 16 || under the circumstances.! 17 6. The parties stipulate that the proposed settlement satisfies each of these factors. It was 18 || negotiated at arms-length in light of the risks, costs, and uncertainties of continued litigation; does 19 || not impair the substantive rights of any non-settling party; reflects amounts reasonably proportional 20 || to the settling Plaintiffs’ claimed damages, discounted for trial risk and litigation expense; was not 21 || entered into for any improper or collusive purpose; and is otherwise fair, reasonable, and in good 22 || faith. 23 |j—___ ' Doctors Company v. Vincent, 120 Nev. 644, 98 P.3d 681 (Nev. 2004) (citing Velsicol Chemical 24 || Corp. vy. Davidson, 107 Nev. 356 (Nev. 1991); In Re: MGM Grand Hotel Fire Litigation, 570 F. Supp. 913 (D. Nev. 1983)).

1 7. Amount Paid in Settlement. The settling parties have agreed to resolve the remaining 2 claims of David Ramirez Torres and Julieth Mateus Munoz in exchange for payment of $25,000 3 |) (Mew money) to each of these two settling Plaintiffs. The amount of the settlement is fair given that 4 || David Ramirez Torres claims $21,988.45 in medical bills related to the 5/22/23 collision, that Julieth 5 || Mateus Munoz claims $19,715.32 in medical bills related to the 5/22/23 collision, and each of these 6 || Plaintiffs have received $25,000 in settlement from their settlement with Defendant Allan Caballero 7 || Enamorado.? As each of the settling Plaintiffs also claims entitlement to general damages for pain 8 || and suffering, this proposed settlement with Defendants Miroslaw Kleczkowski and Sky Dive

9 Logistics, Inc., is proportionate to the settling Plaintiffs’ claimed damages, mitigated by the risk of 10 || trial and cost of litigation. 11 8. The Allocation of Settlement Proceeds Among the Plaintiffs. The parties agree that this 12 || factor does not weigh against a finding of good faith. The settlement allocates equal amounts to each 13 || settling Plaintiff and was negotiated independently of insurance policy limits or collectability 14 || concerns, as the settling Defendants are covered by a commercial liability insurance policy. The 15 || allocation fairly reflects the respective claims and does not prejudice any other party. 16 9. The policy limits of available insurance and the financial condition of the settling 17 || Defendant. This factor likewise does not weigh against a finding of good faith. The settling 18 || Defendants, Miroslaw Kleczkowski and Sky Dive Logistics, Inc., are covered by a policy of 19 || commercial liability insurance, and the settlement was reached without limitation based on policy 20 || limits or concerns regarding collectability. The agreed-upon settlement amount reflects a reasonable 21 || compromise in light of the claims asserted and the risks and costs of continued litigation. 22 23 |j—___ Prior to removal, the state district court entered an order finding that the settling Plaintiffs’ 24 || settlement with Defendant Allan Caballero Enamorado was entered into in good faith pursuant to NR. 17.245.

1 10. Whether the settlement was the product of collusion, fraud, or other tortious conduct 2 || intended to injure the interests of non-settling defendants. The parties stipulate that this factor is 3 |) not applicable to the proposed settlement. The settling Plaintiffs have previously resolved their 4 || claims against all other Defendants; therefore, there are no non-settling Defendants whose rights are 5 || at issue. 6 11. Whether the settlement is otherwise fair and reasonable under the circumstances. The 7 || parties agree that the proposed settlement was the result of an arms-length negotiation between 8 || adverse parties who have entered into this agreement for the sole purpose of mitigating their risk, 9 prosecuting their rights, and amicably resolving their dispute without taking the case through further 10 || protracted litigation. The proposed settlement does not impair the substantive rights of the non- 11 || settling Plaintiffs, and there are no remaining non-settling Defendants whose rights will be affected. 12 12. This settlement agreement resolves all claims asserted by Plaintiffs Julieth Mateus Munoz 13 || and David Ramirez Torres. 14 13. Accordingly, this Court should order the complete dismissal of Plaintiffs Julieth Mateus 15 || Munoz and David Ramirez Torres from the above-captioned suit. 16 14. As of the date of this stipulation, the claims of Plaintiffs Allan I. Caballero Enamorado, Sonia 17 || Y. Caballero Vegas, Eli N. Caballero Enamorado, Miguel A. Ochoa, and Erika Jimenez-Garcia, have 18 || not resolved and remain subject to this Court’s discovery and scheduling orders. 19 15. Accordingly, the instant stipulation does not fully resolve the above-captioned suit. 20 21 22 23 24

1 16. WHEREFORE, the parties respectfully request that the Court enter an order determining that 2 || the Ramirez-Torres Settlement was made in good faith pursuant to NRS 17.245 and dismissing 3 |) Plaintiffs Julieth Mateus Munoz and David Ramirez Torres with prejudice. 4 IT IS SO STIPULATED THIS 26th day of January, 2026, by: 5 6 |) Christopher Beckstrom /s/ Baylie A. Hellman (with permission) Christopher Beckstrom (NV Bar No. 14031) Robert K. Phillips, Esq. 7 || PRICE & BECKSTROM Timothy D. Kuhls, Esq. 1404 S. Jones Blvd. Baylie A. Hellman, Esq. 8 || Las Vegas, Nevada 89146 PHILLIPS, SPALLAS & ANGSTADT LLC Attorney for Plaintiffs David Ramirez Torres 504 South Ninth Street 9 and Julieth Mateus Munoz Las Vegas, Nevada 89101 Attorneys for Defendants Sky Dive Logistics, Inc. 10 and Miroslaw Kleczkowski 11 /s/ Pengxiang Tian (with permission) 12 || Pengxiang Tian, Esq. PT Law 13 || 2820 South Jones Boulevard, Unit 1 Las Vegas, Nevada 89146 14 || Attorney for Plaintiffs Allan Caballero Enamorado, Sonia Caballero Enamorado, Eli 15 || Caballero Enamorado, Miguel Ochoa, and Erika Jimenez-Garcia

16 17 18 IT IS SO ORDERED:

CYS RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE 22 23 DATED: January 27, 2026. 24