Schibye v. Harveys Tahoe Management Company, LLC

Katherine F. Parks, Esq. - State Bar No. 200605 Thorndal Armstrong Delk Balkenbush & Eisinger 6590 S. McCarran Blvd., Suite B Reno, Nevada 89509 (775) 786-2882 [email protected] Attorneys for Defendant HARRAH’S LAUGHLIN, LLC 6 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA LENA SCHIBYE, CASE NO. 2:20-cv-01497-KJM-AC 10 Plaintiff, vs. STIPULATION AND ORDER TO HARRAH’S LAUGHLIN, LLC TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a) 13 Defendants.

Plaintiff, LENA SCHIBYE, and Defendant, HARRAH’S LAUGHLIN, LLC, by and through their undersigned attorneys of record, herby stipulate to transfer this action to the United States District Court, District of Nevada – Reno, pursuant to 28 U.S.C. §§ 1404(a) and the Court’s inherent powers.

WHEREAS, Plaintiff filed her complaint in the Superior Court of California, County of Nevada on June 5, 2020; WHEREAS, Defendant removed Plaintiff’s complaint from the Superior Court of California, County of Nevada to the United States District Court, Eastern District of California on July 24, 2020; WHEREAS, the United States District Court, District of Nevada would have personal jurisdiction over Defendant over the causes of action alleged in the complaint pursuant to 28 3 U.S.C. §1331.

WHEREAS, the Parties have met and conferred and agreed that a transfer of this action to the United States District Court, District of Nevada is appropriate; WHEREAS, 28 U.S.C. §1404(a) permits a district court, in the interests of justice, to transfer a case to another district where venue is proper, and a district court has inherent authority to transfer cases in order to manage its docket. See, Allstar Marketing Group, LLC v. Your Store Online, LLC, 666 F. Supp.2d 1109, 1130 (9th Cir. 2009).

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, subject to the Court’s approval, that: 14 1. This case is hereby transferred to the United States District Court, District of Nevada – Reno.

DATED: This 4th day of September, 2020. DATED this 4th day of September, 2020.

GRAY•DUFFY, LLP THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER By: / s / Kathryn Camerlengo By: / s / Katherine F. Parks 20 555 Twin Dolphin Drive, Suite 300 Katherine F. Parks, Esq.

Redwood City, CA 94065 State Bar No. 200605 T: 650-365-7343 6590 S. McCarran Blvd., Suite B 22 E: [email protected] Reno, Nevada 89509 Attorneys for Plaintiff (775) 786-2882 23 [email protected] Attorneys for Defendant ORDER IT IS SO ORDERED.

28 DATED September 17, 2020.