1 NICHOLAS A. TRUTANICH United States Attorney, District of Nevada 2 Nevada Bar Number 13644 HOLLY A. VANCE 3 Assistant United States Attorney 400 S. Virginia Street, Suite 900 4 Reno, NV 89501 (775) 784-5438 5 [email protected]

6 Attorneys for the United States

7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 MARY KIM PICCININI, and Case No. 3:17-cv-00584-HDM-WGC 10 GEORGE ELDRIDGE & SON, INC.,

ORDER GRANTING 11 Plaintiffs, Joint Motion to Stay Proceedings 12 v.

13 UNITED STATES OF AMERICA,

14 Defendant.

15 16 Defendant United States of America and Plaintiff George Eldridge & Son, Inc. 17 respectfully request this Court to enter a stay of all proceedings and deadlines, including all 18 motion and response deadlines, until March 12, 2020, in order to allow the parties to 19 continue to focus on attempting to settle the case. Currently, the parties are close to 20 reaching a settlement. 21 In support of this joint motion, the parties submit: 22 1. On December 31, 2019, the Court entered an Order of Dismissal with Prejudice 23 (ECF No. 62) as to Plaintiff Mary Kim Piccinini’s claims. George Eldridge & Son, Inc., is 24 the only remaining Plaintiff in the case. 25 2. Eldridge & Son, Inc. and Defendant have recently been attempting to settle the 26 case. Currently, they are close to reaching a settlement that will resolve all outstanding 27 claims between the parties. 1 3. If an agreement is reached and approved by all necessary governmental officials, 2 ||a Compromise Settlement will be executed and request for payment submitted to the 3 || United States’ Treasury. 4 4, Courts have broad discretion to stay proceedings for a limited time. See Landis v. 5 || N. Am. Co.,

(1936); see also, Clinton v. Jones,

(1997) 6 || (courts have broad discretion in the management of cases, including the setting of cases for 7 || trial). 8 5. This joint motion is filed in good faith and not for the purpose of delay. 9 6. If the matter is not concluded by March 12, 2020, the parties will file a motion 10 || asking the Court to lift the stay. 11 7. Neither party will be prejudiced by a stay because trial is not scheduled until June 12 |} 2020. 13 For the above reasons, the parties respectfully request this Court stay the proceedings 14 || and deadlines in this matter until March 12, 2020. 15 Respectfully submitted this 21st day of January, 2020. 16 || Counsel for Plaintiff George NICHOLAS A. TRUTANICH Eldridge & Son, Inc. United States Attorney /s/ Sean P. Rose /s/ Holly A. Vance 18 || SEAN P. ROSE HOLLY A. VANCE Assistant United States Attorney 19 /s/ Thomas R. Brennan 50 THOMAS R. BRENNAN Counsel for Defendant 21 22 23 IT IS SO ORDERED. 24 hbiael’ S td Sh Mh»

26 27 DATED: January 21, 2020 28