LEONARD T. FINK, ESQ. Nevada Bar No. 6296 Nevada Bar No. 11556 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 Telephone: (702) 804-0706 E-Mail: lfink@springelfink.com nduncan@springelfink.com efiling@spingelfink.com
Attorneys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; MARCO SOLORIO; and LEONARD MORRIS
MACK MILLER, an individual; Case No.: 2:23-cv-00070-CDS-DJA
Plaintiff, STIPULATION AND ORDER TO EXTEND vs. [EIGHTH REQUEST] CLARK COUNTY, NEVADA, a political subdivision; DOE CLARK COUNTY OFFICERS, in their personal capacities; DOE PRIVATE SECURITY GUARDS, in their personal capacities; LLC, a domestic limited liability company; MARCO SOLORIO, individually; LEONARD MORRIS, individually; ROE PRIVATE SECURITY COMPANY; DOES 1 through 20; ROE BUSINESS ENTITIES 1 through 20, inclusive jointly and severally,
Defendants.
CLARK COUNTY, a Political Subdivision of State of Nevada,
Cross-Claimant,
vs. PREVENTIVE MEASURES SECURITY FIRM, LLC, a domestic limited liability Company, Cross-Defendant.
IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, and by and through their respective counsel, that the discovery deadlines shall be extended in this matter. I. DISCOVERY COMPLETED TO DATE The parties have participated in the following discovery to date: 1. Plaintiff’s FRCP 26(a)(1) Initial Disclosures; 2. Plaintiff’s FRCP 26(a)(1) First Supplemental Disclosures; 3. Plaintiff’s FRCP 26(a)(1) Second Supplemental Disclosures; 4. Plaintiff’s FRCP 26(a)(1) Third Supplemental Disclosures; 5. Plaintiff’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 6. Plaintiff’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 7. Plaintiff’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 8. Plaintiff’s FRCP 26(a)(1) Seventh Supplemental Disclosures; 9. Plaintiff’s FRCP 26(a)(1) Eighth Supplemental Disclosures; 10. Defendant Clark County’s FRCP 26(a)(1) Initial Disclosures; 11. Defendant Clark County’s FRCP 26(a)(1) First Supplemental Disclosures; 12. Defendant Clark County’s FRCP 26(a)(1) Second Supplemental Disclosures; 13. Defendant Clark County’s FRCP 26(a)(1) Third Supplemental Disclosures; 14. Defendant Preventive Measures’ FRCP 26(a)(1) Initial Disclosures; 15. Defendant Preventive Measures’ FRCP 26(a)(1) First Supplemental Disclosures; 16. Defendant Preventive Measures’ FRCP 26(a)(1) Second Supplemental Disclosures; 17. Defendant Preventive Measures’ FRCP 26(a)(1) Third Supplemental Disclosures; 18. Defendant Clark County’s First Set of Requests for Admissions to Preventive Measures; 19. Defendant Clark County’s First Set of Requests for Production of Documents to Preventive Measures; 20. Defendant Clark County’s First Set of Interrogatories to Preventive Measures; 21. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for Admissions; 22. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for Production of Documents; 23. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Interrogatories; 24. Defendant Clark County’s First Set of Interrogatories to Plaintiff; 25. Defendant Clark County’s First Set of Requests for Admissions to Plaintiff; 26. Defendant Clark County’s First Set of Requests for Production of Documents to Plaintiff; 27. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for Admissions; 28. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for Production of Documents; 29. Plaintiff’s Responses to Defendant Clark County’s First Set of Interrogatories; 30. Defendant Preventive Measures’ First Set of Interrogatories to Plaintiff; 31. Defendant Preventive Measures’ First Set of Requests for Admissions to Plaintiff; 32. Defendant Preventive Measures’ First Set of Requests for Production of Documents to Plaintiff; 33. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Admissions; 34. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Production of Documents; 35. Plaintiff’s Responses to Defendant Preventive Measures First Set of Interrogatories; 36. Plaintiff’s First Set of Interrogatories to Defendant Preventive Measures; 37. Plaintiff’s First Set of Requests for Admissions to Defendant Preventive Measures; 38. Plaintiff’s First Set of Requests for Production to Defendant Preventive Measures; 39. Plaintiff’s First Set of Interrogatories to Defendant Clark County; 40. Plaintiff’s First Set of Requests for Admissions to Defendant Clark County; 41. Plaintiff’s First Set of Requests for Production to Defendant Clark County; 42. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Requests for Admissions to Defendant Preventive Measures; 43. Defendant Clark County’s Responses to Plaintiff’s First Set of Interrogatories to Defendant Clark County; 44. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Admissions to Defendant Clark County; 45. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Production to Defendant Clark County; 46. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Interrogatories and Request for Production; 47. Deposition of Plaintiff (completed February 21, 2024); 48. Deposition of Kate Murray (completed February 15, 2024); 49. Deposition of Brian Cooperman (completed February 15, 2024); 50. Deposition of Elando Johnson (completed February 15, 2024); 51. Plaintiff’s FRCP 26(a)(1) Ninth Supplemental Disclosures; 52. Defendant Clark County’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 53. Defendant Clark County’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 54. Defendant Clark County’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 55. Defendant Preventive Measures’ FRCP
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LEONARD T. FINK, ESQ. Nevada Bar No. 6296 Nevada Bar No. 11556 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 Telephone: (702) 804-0706 E-Mail: lfink@springelfink.com nduncan@springelfink.com efiling@spingelfink.com
Attorneys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; MARCO SOLORIO; and LEONARD MORRIS
MACK MILLER, an individual; Case No.: 2:23-cv-00070-CDS-DJA
Plaintiff, STIPULATION AND ORDER TO EXTEND vs. [EIGHTH REQUEST] CLARK COUNTY, NEVADA, a political subdivision; DOE CLARK COUNTY OFFICERS, in their personal capacities; DOE PRIVATE SECURITY GUARDS, in their personal capacities; LLC, a domestic limited liability company; MARCO SOLORIO, individually; LEONARD MORRIS, individually; ROE PRIVATE SECURITY COMPANY; DOES 1 through 20; ROE BUSINESS ENTITIES 1 through 20, inclusive jointly and severally,
Defendants.
CLARK COUNTY, a Political Subdivision of State of Nevada,
Cross-Claimant,
vs. PREVENTIVE MEASURES SECURITY FIRM, LLC, a domestic limited liability Company, Cross-Defendant.
IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, and by and through their respective counsel, that the discovery deadlines shall be extended in this matter. I. DISCOVERY COMPLETED TO DATE The parties have participated in the following discovery to date: 1. Plaintiff’s FRCP 26(a)(1) Initial Disclosures; 2. Plaintiff’s FRCP 26(a)(1) First Supplemental Disclosures; 3. Plaintiff’s FRCP 26(a)(1) Second Supplemental Disclosures; 4. Plaintiff’s FRCP 26(a)(1) Third Supplemental Disclosures; 5. Plaintiff’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 6. Plaintiff’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 7. Plaintiff’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 8. Plaintiff’s FRCP 26(a)(1) Seventh Supplemental Disclosures; 9. Plaintiff’s FRCP 26(a)(1) Eighth Supplemental Disclosures; 10. Defendant Clark County’s FRCP 26(a)(1) Initial Disclosures; 11. Defendant Clark County’s FRCP 26(a)(1) First Supplemental Disclosures; 12. Defendant Clark County’s FRCP 26(a)(1) Second Supplemental Disclosures; 13. Defendant Clark County’s FRCP 26(a)(1) Third Supplemental Disclosures; 14. Defendant Preventive Measures’ FRCP 26(a)(1) Initial Disclosures; 15. Defendant Preventive Measures’ FRCP 26(a)(1) First Supplemental Disclosures; 16. Defendant Preventive Measures’ FRCP 26(a)(1) Second Supplemental Disclosures; 17. Defendant Preventive Measures’ FRCP 26(a)(1) Third Supplemental Disclosures; 18. Defendant Clark County’s First Set of Requests for Admissions to Preventive Measures; 19. Defendant Clark County’s First Set of Requests for Production of Documents to Preventive Measures; 20. Defendant Clark County’s First Set of Interrogatories to Preventive Measures; 21. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for Admissions; 22. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for Production of Documents; 23. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Interrogatories; 24. Defendant Clark County’s First Set of Interrogatories to Plaintiff; 25. Defendant Clark County’s First Set of Requests for Admissions to Plaintiff; 26. Defendant Clark County’s First Set of Requests for Production of Documents to Plaintiff; 27. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for Admissions; 28. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for Production of Documents; 29. Plaintiff’s Responses to Defendant Clark County’s First Set of Interrogatories; 30. Defendant Preventive Measures’ First Set of Interrogatories to Plaintiff; 31. Defendant Preventive Measures’ First Set of Requests for Admissions to Plaintiff; 32. Defendant Preventive Measures’ First Set of Requests for Production of Documents to Plaintiff; 33. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Admissions; 34. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Production of Documents; 35. Plaintiff’s Responses to Defendant Preventive Measures First Set of Interrogatories; 36. Plaintiff’s First Set of Interrogatories to Defendant Preventive Measures; 37. Plaintiff’s First Set of Requests for Admissions to Defendant Preventive Measures; 38. Plaintiff’s First Set of Requests for Production to Defendant Preventive Measures; 39. Plaintiff’s First Set of Interrogatories to Defendant Clark County; 40. Plaintiff’s First Set of Requests for Admissions to Defendant Clark County; 41. Plaintiff’s First Set of Requests for Production to Defendant Clark County; 42. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Requests for Admissions to Defendant Preventive Measures; 43. Defendant Clark County’s Responses to Plaintiff’s First Set of Interrogatories to Defendant Clark County; 44. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Admissions to Defendant Clark County; 45. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Production to Defendant Clark County; 46. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Interrogatories and Request for Production; 47. Deposition of Plaintiff (completed February 21, 2024); 48. Deposition of Kate Murray (completed February 15, 2024); 49. Deposition of Brian Cooperman (completed February 15, 2024); 50. Deposition of Elando Johnson (completed February 15, 2024); 51. Plaintiff’s FRCP 26(a)(1) Ninth Supplemental Disclosures; 52. Defendant Clark County’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 53. Defendant Clark County’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 54. Defendant Clark County’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 55. Defendant Preventive Measures’ FRCP 26(a)(1) Fourth Supplemental Disclosures; 56. Defendant Preventive Measures’ FRCP 26(a)(1) Fifth Supplemental Disclosures; 57. Defendant Preventive Measures’ FRCP 26(a)(1) Sixth Supplemental Disclosures; 58. Defendant Preventive Measures’ FRCP 26(a)(1) Seventh Supplemental Disclosures; 59. Plaintiff’s FRCP 26(a)(1) Tenth Supplemental Disclosures; 60. Deposition of Chief James Rogers (completed on May 9, 2024); 61. Deposition of Defendant Clark County’s FRCP 30(b)(6) designee(s) (completed on June 11, 2024); 62. Deposition of David Sutton/FRCP 30(b)(6) designee(s) for Defendant Preventive Measures (completed June 27, 2024). 63. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Requests for Production (completed July 18, 2024); 64. Defendant Clark County’s Eighth Supplemental FRCP 26 Disclosure and Production of Documents (completed July 31, 2024); 65. Defendant Clark County’s Supplemental Answers to Plaintiff’s First Set of Interrogatories (completed August 1, 2024); 66. Defendant Clark County’s Supplemental Responses to Plaintiff’s First Set of Requests for Production of Documents (completed August 1, 2024); 67. Plaintiff’s Initial Designation of Expert Witnesses (completed August 15, 2024); 68. Plaintiff’s FRCP 26(a)(1) Eleventh Supplemental disclosures (completed September 3, 2024); 69. Inspection of the area of the subject incident at The Clark County Government Center (completed September 4, 2024); 70. Plaintiff noticed the deposition of Preventive ex-employee Defendant Marco Solorio for September 20, 2024; 71. Defendant Preventive Measures noticed the Rule 35 Exam of Incarcerated Plaintiff, Mack Miller (occurred October 11, 2024); 72. Defendant Preventative Measures Eighth Supplemental Disclosures (completed November 6, 2024); 73. Defendant Preventative Measures Ninth Supplemental Disclosures (completed November 12, 2024); 74. Defendant Preventative Measures Initial Expert Disclosures (completed November 12, 2024); 75. Plaintiff’s Noticed Deposition of Leonard Morris (completed November 13, 2024); 76. Plaintiff’s FRCP 26(a)(1) Twelfth Supplemental disclosures (completed November 14, 2024); 77. Defendant Preventative Measures Tenth Supplemental Disclosures (completed December 17, 2024); 78. Defendant Preventative Measures Rebuttal Expert Disclosures (completed December 17, 2024). 79. Defendant Preventative Measures Eleventh Supplemental Disclosures (completed February 24, 2025); 80. Defendant Preventative Measures Twelfth Supplemental Disclosures (completed March 5, 2025); 81. Plaintiff’s FRCP 26(a)(1) Thirteenth Supplemental disclosures (completed January 28, 2025); 82. Defendant Preventive Measures Noticed Deposition of Mark Meredith (completed January 30, 2025); and 83. Plaintiff’s Noticed Deposition of Steve Kaufer CPP (completed January 28, 2025); 1. Depositions of other fact witnesses present at the County Commission meeting during the subject incident; 2. Deposition of parties’ treating physicians and/or experts; 3. Any additional discovery that is necessary as the parties proceed through discovery; 4. Defendant Preventative Measures Deposition of Judith Leslie (coordination of a date for deposition is currently in process); 5. Defendant Preventive Measures Deposition of John DiMuro, MD (coordination of a date for deposition is currently in process; 6. Defendant Preventative Measures Noticed Deposition of Adam West, DO, noticed for April 30, 2025; and 7. Defendant Preventative Measures has outstanding Subpoenas duces tecum for records that it has not received as of the date of this Stipulation. III. REASONS WHY DISCOVERY NOT COMPLETED WITHIN TIME SET BY A motion to extend deadlines articulated in the Court’s Scheduling Order must be supported by a showing of good cause. See Local Rule 26-3; see also Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608-09 (9th Cir. 1992). Good cause to extend a deadline exists if it cannot reasonably be met despite the diligence of the party seeking extension. Johnson, 975 F.2d at 609. In the instant matter, all parties have diligently attempted to comply with the Court’s Scheduling Order – however, the parties have determined they require additional time to obtain and produce key evidence related to the incident and alleged damages. Without this necessary evidence the parties’ experts are likely deprived the ability to formulate their opinions, complete their evaluations and prepare their reports accordingly, as well as impairs counsels’ ability to reach a proper determination as to further discovery needed. On July 2, 2024, the parties entered a stipulation to extend the discovery deadlines primarily based on the need for additional time to take depositions, due to new counsel recently associating in for Preventative Measures. Since that time, a Substitution of Counsel for Preventive Measures, Marco Solorio, and Leonard Morris [ECF No. 45] was filed with the Court on September 5, 2024. The parties diligently completed additional written discovery, a couple depositions and a site inspection since the last stipulation. During that time, in addition Preventive Measures completed its Rule 35 medical exam of Plaintiff, Mack Miller, who is currently incarcerated at Three Lakes Valley Conservation Camp at Southern Desert Correctional Center. Preventative measures has disclosed the Rule 35 medical report to all parties. On January 22, 2025, the parties entered into a further Stipulation to extend discovery deadlines, due to Preventative coordinating dates for the depositions of fact witnesses. The parties have limited contact information for these witnesses, therefore it has taken additional time to secure depositions with them. Preventative now has the deposition dates secured, but additional time is needed for the depositions. On April 18, 2025, the parties entered into a further Stipulation to extend the dispositive motion deadline, due to Preventative coordinating dates for the depositions of fact witnesses. The parties have limited contact information for these witnesses, therefore Preventative requires additional time to secure depositions with them. Preventative had the deposition dates secured, but a change in circumstances required the dates to be rescheduled. Preventive is currently coordinating available dates with all counsel and witnesses. The remaining witness depositions and expert depositions will be critical to the claims and defenses in the instant action and will have a direct impact on the opinions of the parties’ retained experts. Accordingly, the parties respectfully request that the dispositive motion deadline be extended an additional Sixty (60) days. The requested extension will ensure all parties have a full and fair opportunity to litigate the claims and defenses on the merits. Therefore, and as set forth below, due diligence and good cause can be shown to allow the Court, in its discretion, to extend the remaining deadline as requested. Based on the foregoing, the proposed schedule for completing discovery is as follows:
Discovery Deadline Current Deadline Proposed Deadline Close of Discovery 3/22/2025 5/20/2025 Dispositive Motions 4/24/2025 6/30/2025
DATED this 18th of April 2025. DATED this 18th of April 2025.
SPRINGEL & FINK LLP RICHARD HARRIS LAW FIRM
By: /s/ Nakesha S. Duncan-Perez By: /s/ Jonathan B. Lee (w/permission) . . LEONARD T. FINK, ESQ. JONATHAN B. LEE, ESQ. Nevada Bar No. 6296 Nevada Bar Number 13524 NAKESHA S. DUNCAN-PEREZ, ESQ. 801 South Fourth Street Nevada Bar No. 11556 Las Vegas, Nevada 89101 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 Attorneys for Plaintiff, Attorneys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; MARCO SOLORIO; and LEONARD MORRIS
DATED this 18th of April 2025.
CLARK COUNTY DISTRICT ATTORNEY
By: /s/ Joel K. Browning (w/permission) . JOEL K. BROWNING, ESQ. Nevada Bar No. 14489 500 South Grand Central Parkway, Ste. 5075 Las Vegas, Nevada 89155 Attorneys for Defendant/Cross-Claimant, CLARK COUNTY, NEVADA
Mack Miller v Clark County, NV, et al. Case No. 2:23-cv-00070-CDS-DJA Stipulation and Order to Extend Discovery Deadlines (Eighth Request) Pursuant to the Stipulation of the parties and good cause appearing, the discovery deadlines are extended as follows: Discovery Deadline | Current Deadline | Proposed Deadline Close of Discove 3/22/2025 5/20/2025 4/24/2025 6/30/2025 ! IT IS SO ORDERED.
UNITED STATESJMAGISTRATE JUDGE +g || Respectfully submitted, By: /s/ Nakesha S. Duncan-Perez LEONARD T. FINK, ESQ. Nevada Bar No. 6296 Nevada Bar No. 11556 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 Attomeys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; MARCO SOLORIO; and LEONARD MORRIS
From: Joel Browning Sent: Friday, April 18, 2025 2:05 PM To: Phaedra L. Calaway ; Jonathan Lee Cc: Nakesha Duncan-Perez ; Leonard Fink Subject: Re: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. You may affix my signature. Thanks. Get Outlook for Android From: Phaedra L. Calaway Sent: Friday, April 18, 2025 1:57:33 PM To: Jonathan Lee ; Joel Browning Cc: Nakesha Duncan-Perez ; Leonard Fink Subject: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. CAUTION: This email originated from an External Source. Please use caution before opening attachments, clicking links, or responding to this email. Do not sign-in with your DA account credentials. Dear Counsel, Attached please find for your review a draft of the following document entitled Stipulation and Order to Extend Discovery Deadlines (Eighth Request) (“Stipulation”) for your review. If the Stipulation meets with your approval please advise and if acceptable, please advise if we may execute the Stipulation on your behalf. Should you have any questions regarding the attached please do not hesitate to contact either me or Ms. Duncan-Perez at your earliest convenience so that we may present the Stipulation to the Court. Thank you. Phaedra L. Calaway Legal Assistant to Attorney Nakesha S. Duncan-Perez op wb ate) Woes spb aie AT T O FP BW ET @ ~ T a 9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148 Tel: (702) 804-0706
From: Jonathan Lee Sent: Friday, April 18, 2025 2:08 PM To: Phaedra L. Calaway ; Joel.Browning@clarkcountyda.com Cc: Nakesha Duncan-Perez ; Leonard Fink Subject: Re: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. You may affix mine as well. Jonathan Lee Lawyer - Partner Direct (702) 444-4429
Las Vegas Reno 801 South 4th Street 6900 S. McCarran Blvd., #1010 Las Vegas NV 89101 Reno NV 89509 Ph. (702) 444-4444 x 229 Ph. (775) 222-2222
Legal Disclaimer From: Phaedra L. Calaway Sent: Friday, April 18, 2025 1:57 PM To: Jonathan Lee ; Joel.Browning@clarkcountyda.com Cc: Nakesha Duncan-Perez ; Leonard Fink Subject: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear Counsel, Attached please find for your review a draft of the following document entitled Stipulation and Order to Extend Discovery Deadlines (Eighth Request) (“Stipulation”) for your review. If the Stipulation meets with your approval please advise and if acceptable, please advise if we may execute the Stipulation on your behalf.
Should you have any questions regarding the attached please do not hesitate to contact either me or Ms. Duncan-Perez at your earliest convenience so that we may present the Stipulation to the Court. Thank you. Phaedra L. Calaway Legal Assistant to Attorney Nakesha S. Duncan-Perez ro) oun atexc) Arcee bb a=
9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148 Tel: (702) 804-0706 | Fax: (702) 804-0798