Opinion
2:23-cv-00977-JCM-NJK
08-08-2023
GC, a minor, by and through her natural parent and legal guardian, JANICE COFIELD; ANTHONY M. RICCIARDI, JR., DPM, an individual, Plaintiffs, v. DOCTORS PROFESSIONAL LIABILITY RISK RETENTION GROUP, INC., a foreign corporation; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.
PRINCE LAW GROUP DENNIS M. PRINCE Nevada Bar No. 5092 KEVIN T. STRONG Nevada Bar No. 12107 Attorneys for Plaintiffs GC, a Minor by and through Her Natural Parent and Legal Guardian, Grace Cofield and Anthony M. Ricciardi, Jr., DPM KING SCOW KOCH DURHAM LLC GREGORY H. KING Nevada Bar No. 7777 MATTHEW L. DURHAM Nevada Bar No. 10342 Attorneys for Defendant Doctors Professional Liability Risk Retention Group, Inc.
PRINCE LAW GROUP
DENNIS M. PRINCE Nevada Bar No. 5092
KEVIN T. STRONG Nevada Bar No. 12107
Attorneys for Plaintiffs GC, a Minor by and through Her Natural Parent and Legal Guardian, Grace Cofield and Anthony M. Ricciardi, Jr., DPM
KING SCOW KOCH DURHAM LLC
GREGORY H. KING Nevada Bar No. 7777
MATTHEW L. DURHAM Nevada Bar No. 10342
Attorneys for Defendant Doctors Professional Liability Risk Retention Group, Inc.
STIPULATION AND ORDER TO ALLOW PLAINTIFFS TO FILE A COMPLETE AND ACCURATE COPY OF THEIR COMPLAINT WITH EXHIBITS
IT IS HEREBY STIPULATED AND AGREED, between Plaintiffs GC, a minor, by and through her natural parent and legal guardian, JANICE COFIELD and ANTHONY M. RICCIARDI, JR., DPM, through their counsel of record, Dennis M. Prince and Kevin T. Strong of PRINCE LAW GROUP; and Defendant DOCTORS PROFESSIONAL LIABILITY RISK RETENTION GROUP, INC., through its counsel of record, Gregory H. King and Matthew L. Durham of KING SCOW KOCH DURHAM LLC that Plaintiffs shall be permitted to file a complete and accurate copy of their Complaint in this action as explained below.
1. On May 23, 2023, Plaintiffs filed their Complaint in the Eighth Judicial District Court, Clark County, Nevada, Case No. A-23-871151-C.
2. Throughout the Complaint, Plaintiffs specifically refer to two separate exhibits. Due to a clerical error, Plaintiffs omitted those exhibits when they filed their Complaint in the Eighth Judicial District Court, Clark County, Nevada.
3. On June 25, 2023, Defendant filed its Notice of Removal Pursuant to 28 U.S.C. §§ 1332, 1441, and 1446. (ECF No. 5). Defendant attached Plaintiffs' file-stamped copy of their Complaint as Exhibit A to its Notice of Removal. (ECF No. 5-1).
4. The current version of Plaintiffs' Complaint on file herein is incomplete and not accurate solely because the two exhibits Plaintiffs reference therein were not attached to the Complaint when Plaintiffs originally filed it. This Stipulation is solely intended to correct that clerical error. ... ...
Based on the foregoing, the parties respectfully request this Court to approve the foregoing stipulation and allow Plaintiffs to file a complete and accurate copy of their Complaint in this action that includes a copy of the two exhibits expressly referenced therein.
ORDER
IT IS SO ORDERED.