Lewis v. Thor Motor Coach, Inc.

District Court, D. Nevada

Lewis v. Thor Motor Coach, Inc.

Trial Court Opinion

1 A.J. Kung, Esq. Nevada Bar No. 7052 2 KUNG & BROWN 1020 Garces Ave. 3 Las Vegas, NV 89101 4 (702)382-0883 Telephone (702)382-2720 Facsimile 5 [email protected] Counsel for Plaintiff 6 Stephen Lewis 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 * * * 10 11 STEPHEN LEWIS, an Individual, CASE NO.: 2:24-cv-02371-JCM-DJA 12 Plaintiff, STIPULATION FOR DISMISSAL 13 v. WITH PREJUDICE 14 THOR MOTOR COACH, INC., a Delaware 15 Corporation licensed and doing business in Nevada; RV RETAILER IDAHO, LLC DBA 16 BLUE COMPASS RV, a Delaware Limited- Liability Company doing business in Nevada; 17 TRENT BROIDE, a Nevada Resident; HAL’S RV, LTD, a Nevada Limited-Liability 18 Company; GENERAL RV CENTER, INC., a 19 Michigan Corporation; DOES I-X; ROE BUSINESS ENTITIES XI-XX, 20 Defendants. 21 22 23 24 25 / / / 26 / / / 27 28 / / / 1 Pursuant to the settlement agreement reached by the parties, the undersigned parties 2 hereby stipulate and agree to dismissal of Plaintiff’s Complaint, with prejudice; with each party 3 to bear their own fees and costs. 4 5 DATED this _3_rd_ day of March 2025. DATED this _3_rd_day of March2025. 6 7 KUNG & BROWN CHAMPION LOVELOCK LAW 8 /s/ A.J. K ung /s/ Tracy M. O'Steen A.J. Kung, Esq. Tracy M. O'Steen, Esq. 9 1020 Garces Avenue 6600 Amelia Earhart Ct., Suite A 10 Las Vegas, Nevada 89101 Las Vegas, Nevada89119 Counsel for Plaintiff Stephen Lewis Counsel for Defendants Thor Motor 11 Coach, Inc. and General RV Center, Inc. 12 13 DATED this _3_rd_day of March 2025. DATED this ___ day of March 2025. 14 15 ROBERTSON, JOHNSON, MILLER HAL’S RV, LTD. 16 & WILLIAMSON 17 /s/ Richa rd D. W illiamson James Halford, Managing Member Richard D. Williamson, Esq. 1003 Companion Way 18 50 West Liberty Street, Suite 600 Henderson, Nevada 89011 Reno, Nevada 89501 Pro-Se Defendant 19 Counsel for Defendant RV Retailer Idaho, 20 LLC dba Blue Compass 21 22 DATED this ___ day of March 2025. 23 24 25 Trent Broide 26 11516 NV 16th Avenue Vancouver, Washington 98685 27 Pro-Se Defendant 28 1 Pursuant to the settlement agreement reached by the parties, the undersigned parties 2 hereby stipulate and agree to dismissal of Plaintiff's Complaint, with prejudice; with each party 3 to bear their own fees and costs. || DATED this ___day of March 2025. DATED this ___ day of March 2025. 7 || KUNG & BROWN CHAMPION LOVELOCK LAW 8 A.J. Kung, Esq. Andrea M. Champion, Esq. ? 1020 Garces Avenue 6600 Amelia Earhart Ct., Suite A 19 || Las Vegas, Nevada 89101 Las Vegas, Nevada 89119 Counsel for Plaintiff Stephen Lewis Counsel for Defendants Thor Motor il Coach, Inc. and General RV Center, Inc. 12 8 23 & 13 <8 x DATED this ___ day of March 2025. DATED this 3rd day of March 2025. 14

!5 1 ROBERTSON, JOHNSON, MILLER HAL’S RV, LTD. 88 & WILLIAMSON 3 16 = [ames Halford & 17 James Halford, Managing Member Richard D. Williamson, Esq. 1003 Companion Way 18 50 West Liberty Street, Suite 600 Henderson, Nevada 8901 1 19 Reno, Nevada 89501 Pro-Se Defendant Counsel for Defendant RV Retailer Idaho, 20 LLC dba Blue Compass 21 22 | DATED this day of March 2025. 23 24 25 Trent Broide 26 |

11516 NV 16

" Avenue Vancouver, Washington 98685 Pro-Se Defendant 28

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l Pursuant to the settlement agreement reached by the parties, the undersigned parties. 2 || hereby stipulate and agree to dismissal of Plaintiff's Complaint, with prejudice; with each party 3 to bear their own fees and costs. 51] DATED this day of March 2025. DATED this __ day of March 2025. 7 || KUNG & BROWN CHAMPION LOVELOCK LAW 8 A.J. Kung, Esq. Andrea M. Champion, Esq. 9 1020 Garces Avenue 6600 Amelia Earhart Ct., Suite A 19 || Las Vegas, Nevada 89101 Las Vegas, Nevada 89119 Counsel for Plaintiff Stephen Lewis Counsel for Defendants Thor Motor il Coach, Inc. and General RV Center, Inc. a 12 Zz Sa Zo 13 “3 DATED this _ day of March 2025. DATED this _ day of March 2025. 14

15 ROBERTSON, JOHNSON, MILLER HAL’S RV, LTD. m 1} & WILLIAMSON 2 17 James Halford, Managing Member Richard D. Williamson, Esq. 1003 Companion Way 18] 50 West Liberty Street, Suite 600 Henderson, Nevada 89011 19 Reno, Nevada 89501 Pro-Se Defendant Counsel for Defendant RV Retailer Idaho, 20 LLC dba Blue Compass 21 oo“ 22 || DATED this | day of March 2025. 23 24 || . ys) Trent Broide 26 |

11516 NV 16

" Avenue 7 Vancouver, Washington 98685 Pro-Se Defendant 28 Page 2 of 3

1 ORDER 2 IT IS SO ORDERED that the Stipulation for Dismissal with Prejudice is GRANTED. 3 4 5 DATED: March 19, 2025. 6 UNITED STATES DISTRICT JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 From: Tracy O’Steen <[email protected]> Sent: Monday, March 3, 2025 12:14 PM To: Kat Thomas; Philip C. Brashier; John Sear; AJ Kung; Matthew Cline Cc: Andrea Champion; Julie Linton; Lorie Januskevicius Subject: RE: Lewis v. Thor Motor Coach, et al. Follow Up Flag: Follow up Flag Status: Flagged Good afternoon, You have permission to e-sign the Stipulation to Dismiss with Prejudice on behalf of counsel for Thor and General RV. Please let me know if you need anything further. Best, TRACY M. O’STEEN, ESQ. | CHAMPION LOVELOCK LAW 6600 Amelia Earhart Ct., Ste. A, Las Vegas, NV 89119 P (702) 805-8450 | F (702) 805-8451 [email protected] | www.championlawvegas.com Please note the change of our firm name, website, and email addresses. CONFIDENTIALITY NOTICE: This e-mail message is a confidential communication from Champion Lovelock Law and is intended only for the named recipient(s) above and may contain information that is a trade secret, proprietary, privileged or attorney work product. If you have received this message in error, or are not the named or intended recipient(s), please immediately notify the sender and delete this e-mail message and any attachments from your workstation or network mail system. From: Kat Thomas <[email protected]> Sent: Monday, March 3, 2025 12:05 PM To: Tracy O’Steen <[email protected]>; Philip C. Brashier <[email protected]>; John Sear <[email protected]>; AJ Kung <[email protected]>; Matthew Cline <[email protected]> Cc: Andrea Champion <[email protected]>; Julie Linton <[email protected]>; Lorie Januskevicius <[email protected]> Subject: RE: Lewis v. Thor Motor Coach, et al. Importance: High Good afternoon All: I hope this email finds you well. Please find attached hereto, the Stipulation for Dismissal with Prejudice for your review/approval. Please note that pursuant to the Court’s Minute Order dated February 3, 2025, the Stipulation needs to be filed today. Please execute and return as soon as possible. Thank you! As always, should you have any questions, comments or concerns, please do not hesitate to contact our From: Rich Williamson <[email protected]> Sent: Monday, March 3, 2025 1:10 PM To: Philip C. Brashier; Kat Thomas Cc: Andrea Champion; Julie Linton; Lorie Januskevicius; Tracy O’Steen; John Sear; Matthew Cline; AJ Kung; George A. Kurisky, Jr.; Amanda I. Zayid; Lauren M. Chandler Subject: RE: Lewis v. Thor Motor Coach, et al. Follow Up Flag: Follow up Flag Status: Flagged Kat, As noted, you have my permission to affix my electronic signature. Thanks, Rich ____________________________________ Richard D. Williamson, Esq. Robertson, Johnson, Miller & Williamson 50 West Liberty Street, Suite 600 Reno, Nevada 89501 Telephone: (775) 329-5600 Facsimile: (775) 348-8300 Email: [email protected] Please visit our Website at: www.nvlawyers.com IMPORTANT NOTICE: PERSONAL AND CONFIDENTIAL. This message, and any file(s) or attachment(s) transmitted with it, is intended only for the named recipient, may be confidential, and may contain information that is a trade secret, proprietary, protected by the attorney work-product doctrine, subject to the attorney-client privilege, or is otherwise protected against unauthorized use or disclosure. All information contained in or attached to this message is transmitted based on a reasonable expectation of privacy consistent with ABA Formal Opinion No. 99-413. Any disclosure, distribution, copying, or use of this information by anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you receive this message in error, please advise the sender by immediate reply and completely delete the original message (which includes your deleted items folder). Personal messages express only the view of the sender and are not attributable to Robertson, Johnson, Miller & Williamson. We advise you that any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter addressed herein. TRANSMISSION OF THIS INFORMATION IS NOT INTENDED TO CREATE, AND RECEIPT DOES NOT CONSTITUTE, AN ATTORNEY-CLIENT RELATIONSHIP. From: Philip C. Brashier <[email protected]> Sent: Monday, March 3, 2025 12:16 PM

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