Wynn Holdings, LLC v. Rolls-Royce Motor Cars NA, LLC

District Court, D. Nevada

Wynn Holdings, LLC v. Rolls-Royce Motor Cars NA, LLC

Trial Court Opinion

1 Nicole Lovelock Nevada Bar No. 11187 2 Justin C. Jones Nevada Bar No. 8519 3 JONES LOVELOCK 6675 S. Tenaya Way, Suite 200 4 Las Vegas, NV 89113 Tel: 702/805-8450 5 Fax: 702/805-8451 [email protected] 6 [email protected]

7 Richard L. Stuhlbarg Nevada Bar No. 9698 8 BOWMAN AND BROOKE LLP 970 W. 190th Street, Suite 700 9 Torrance, CA 90502 Tel: 310/ 768-3068 10 Fax: 310/ 719-1019 [email protected] 11 Attorneys for Defendants, 12 ROLLS-ROYCE MOTOR CARS, NA, LLC and TOWBIN MOTOR CARS, LLC 13

14 UNITED STATES DISTRICT COURT

15 DISTRICT OF NEVADA

16 WYNN HOLDINGS, LLC, a Montana limited Case No. 2:17-cv-00127-RFB-DJA liability company, 17 Plaintiff, Judge: Hon. Richard F. Boulware, III 18 Magistrate Judge: Hon. Daniel J. Albregts v. 19 ROLLS-ROYCE MOTOR CARS NA, LLC, a STIPULATION AND ORDER FOR DISMISSAL 20 Delaware limited liability company; TOWBIN WITH PREJUDICE MOTOR CARS, LLC, a Nevada limited 21 liability company; DOES I through X, inclusive; and ROE CORPORATIONS .I 22 through X, inclusive,

23 Defendants. 24

25 / / / 26 / / / 27

28 1 1 STIPULATION AND ORDER FOR DISMISSAL WITH PREJUDICE 2 IT IS HEREBY STIPULATED AND AGREED by and between all of the above-named 3 parties by and through their undersigned counsel of record that the entirety of this action is hereby 4 dismissed, with prejudice pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, 5 each party to bear its own costs including experts and attorneys' fees incurred herein. 6 / / / 7 / / / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 1 IT IS FURTHER STIPULATED AND AGREED that as a separate negotiated element of 2 || this Stipulation, the terms of the settlement agreement between Plaintiff and Defendants, along with 3 || the amount of consideration shall remain confidential. 4 Respectfully submitted, 5 BOWMAN AND BROOKE LLP 6 7 || Dated: December 9, 2020 By: /s/ Richard L. Stuhlbarg Richard L. Stuhlbarg 8 Nevada Bar No. 9698 BOWMAN AND BROOKE LLP 9 970 W. 190th Street, Suite 700 Torrance, CA 90502 10 1] Attorneys for Defendants ROLLS-ROYCE MOTOR CARS NA and 12 TOWBIN MOTOR CARS, LLC 13 14 HONG & HONG LAW OFFICE

15 Dated: December 16, 2020 By: /s/ Joseph Y. Hong 16 Joseph Y. Hong Nevada Bar No. 005995 17 HONG & HONG LAW OFFICE 1980 Festival Plaza Drive, Suite 650 18 Las Vegas, NV 89135 19 Attorney for Plaintiff 20 ORDER 21 IT IS SO ORDERED: 22 23 = < 24 RICHARD F. BOULWARE, II 25 United States District Judge 26 DATED this day of December, 2020. 27 28

STIPULATION AND ORDER FOR DISMISSAL WITH PREJUDICE = Case No. 2:17-cv-00127-RFB-DJA 23558537v3

1 CERTIFICATE OF SERVICE

2 3 I hereby certify that on the 16th day of December, 2020, I electronically the foregoing 4 documents with the Clerk of this Court, using the CM/ECF System. In accordance with the 5 electronic filing procedures of this Court, service has been effected on the aforesaid party(s) above, 6 whose counsel of record is a registered participant of CM/ECF, via electronic service through the 7 CM/ECF system. 8 I declare under penalty of perjury that the foregoing is true and correct, and that I am 9 employed at the office of a member of the bar of this Court at whose direction the service was made. 10 Executed on December 16, 2020, at Torrance, California.

11 BOWMAN AND BROOKE LLP

12 By: /s/ Richard L. Stuhlbarg 13 Richard L. Stuhlbarg Nevada Bar No. 9698 14 BOWMAN AND BROOKE LLP 970 W. 190th Street, Suite 700 15 Torrance, CA 90502

16 17 18 19 20 21 22 23 24 25 26 27 28 4 1 PROOF OF SERVICE F.R.C.P. Rule 5(b)(2) 2 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not 3 || a party to the within action; my business address 1s

970 W. 190

" Street, Suite 700, Torrance, CA 90502. 4 I hereby certify that on December 16, 2020, I served the foregoing document: STIPULATION AND ORDER FOR DISMISSAL on: 5 Joseph Y. Hong, Esq. 6 || HONG & HONG LAW OFFICE 1980 Festival Plaza Drive, Suite 650 7 || Las Vegas, Nevada 89135 8 || Attorneys for Plaintiff 9 || as follows: 10 || () BY MAIL (F.R.C.P. Rule 5(b)(2)) I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, I sealed such document(s) in 11 separate envelopes for each addressee and deposited each for collection and mailing with U.S. postal service on that same day with postage thereon fully prepaid at Torrance, California in the 12 ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of 13 deposit for mailing in affidavit. 14 || BY OVERNIGHT DELIVERY (F.R.C.P. Rule 5(b)(2)) Iam "readily familiar" with the firm's practice of collection and processing documents for mailing. Under the practice, the envelope 15 would be put in a sealed envelope and deposited with the U.S. postal service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the 16 party served, service is presumed invalid if postal cancellation date or postage date is more than 1 day after date of deposit for mailing in affidavit. 17 BY ELECTRONIC SERVICE: Based on an agreement of the parties to accept service by 18 electronic transmission, I caused the documents to be sent to the addressees persons at the electronic notification listed on the Service/Mailing List. 19 (X) BY CM/ECF: I hereby certify that I electronically transmitted the attached document(s) to the 20 Clerk’s Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the parties as shown on the attached Service List. 21 BY PERSONAL SERVICE (F.R.C.P. 5(2)): I delivered such envelope by hand to the 22 addressee. 23 Executed on December 16, 2020, at San Pedro, California. 24 || (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. . 25 funily plalle- 26 Emily Zabatta 27 28 STIPULATION AND ORDER FOR DISMISSAL WITH PREJUDICE = Case No. 2:17-cv-00127-RFB-DJA 23558537v3

Reference

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