Opinion
2:21-cv-02192-JCM-DJA
04-03-2023
JASON LOWE, Plaintiff, v. WALMART, INC. DBA WALMART NEIGHBORHOOD MARKET #4339 a Nevada Domestic Limited Liability Company; SECURITAS SECURITY SERVICES USA, INC., a Foreign Corporation; DOES 1 through 30; ROE BUSINESS ENTITIES 1 through 30; DOE STAFF MEMBERS 1 through 30, inclusive, Defendants.
LEONARD T. FINK, ESQ. NAKESHA S. DUNCAN-PEREZ, ESQ. CHAD D. FUSS, ESQ. SPRINGEL & FINK LLP SECURITAS SECURITY SERVICES USA, INC.
LEONARD T. FINK, ESQ.
NAKESHA S. DUNCAN-PEREZ, ESQ.
CHAD D. FUSS, ESQ.
SPRINGEL & FINK LLP
SECURITAS SECURITY SERVICES USA, INC.
STIPULATION AND ORDER TO DISMISS PLAINTIFF'S COMPLAINT WITH PREJUDICE
Defendant, SECURITAS SECURITY SERVICES USA, INC.'S (“SECURITAS”), Defendant, WALMART, INC. dba WALMART NEIGHBORHOOD MARKET #4339, and Plaintiff, JASON LOWE (“Plaintiff') by and through their respective counsels of record, stipulate that:
1. Plaintiffs Complaint against Defendants, and all amendments thereto, are dismissed with prejudice; and
2. Each party is to bear its own attorneys' fees and costs.
IT IS SO STIPULATED.
ORDERED
IT IS HEREBY ORDERED.
From: Ian Estrada
To: Chad D. Fuss; Madison Aguirre: Nakesha Duncan-Perez; Karina Rosas
Cc: Alma Duarte
Subject: Re: Lowe v. Walmart/Securitas
Dated: Wednesday, March 22, 2023 12:20:40 PM
Chad, please go ahead and use my e-signature.
And thanks for putting this together. (I know I said I'd do it; so, thank you)
Thanks, Ian
From: Chad D. Fuss <cfuss@springelfink.com>
Dated: Wednesday, March 22, 2023 at 12:16 PM
To: Madison Aguirre <MAguirre@AlversonTaylor.com>, Ian Estrada
<lan@richardharrislaw.com>, Nakesha Duncan-Perez<nduncan@springelfink.com>, Karina
Rosas <krosas@richardharrislaw.com>
Cc: Alma Duarte <aduarte@springelfink.com>
Subject: RE: Lowe v. Walmart/Securitas
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Ian and Madison
Attached is a draft stipulation to dismiss. Please let us know if we can use your electronic signatures on it.
Thank you.
Chad D. Fuss
Attorney
(Image Omitted)
9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148
Tel: (702) 804-0706 | Fax: (702) 804-0798
From: Madison Aguirre <MAguirre@AlversonTaylor.com>
Sent: Thursday, March 16, 2023 8:40 AM
To: 'Ian Estrada' <lan@richardharrislaw.com>; Chad D. Fuss <cfuss@springelfink.com>; Nakesha
Duncan-Perez <nduncan@springelfink.com>; Karina Rosas <krosas@richardharrislaw.com> Subject: RE: Lowe v. Walmart/Securitas
Good morning, That is accurate.
Thank you.
Madison Aguirre
Alverson Taylor & Sanders
702.384.7000 alversontaylor.com
From: Ian Estrada <lan@richardharrislaw.com>
Sent: Wednesday, March 15, 2023 7:06 PM
To: Chad D. Fuss <cfuss@sDringelfink.com>: Nakesha Duncan-Perez < n d u nca.n@sprin ge If ink, co m>; Madison Aguirre <MAguirre@AlversonTaylor.com>: Karina Rosas <krosas@richardharrislaw.com>
Subject: Lowe v. Walmart/Securitas
Chad and Madison, This is to confirm that both of your clients have agreed to a walk away. Mr. Lowe will dismiss your clients with prejudice and each party will cover their own fees and costs.
If this is not accurate, please let me know.
I will circulate a SAO to Dismiss shortly.
Thanks, Ian
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From: Kurt Bonds
To: Chad D. Fuss: Madison Aguirre: "Ian Estrada"; Nakesha Duncan-Perez; Karina Rosas
Cc: Alma Duarte
Subject: RE; Lowe v. Walmart/Securitas
Dated: Wednesday, March 22, 2023 12:31:21 PM
Attachments: image002.png
This works for us on behalf of Walmart. Kurt.
Kurt Bonds, Esq.
(Image Omitted)
6605 Grand Montecito Pkwy., Suite 200, Las Vegas, NV 89149 702.384.7000 Office | 702.385.7000 Fax
website | bit) | vCard | map | email
From: Chad D. Fuss <cfuss@springelfink.com>
Sent: Wednesday, March 22, 2023 12:16 PM
To: Madison Aguirre <MAguirre@AlversonTaylor.com>; 'Ian Estrada' <lan@richardharrislaw.com>; Nakesha Duncan-Perez <nduncan@springelfink.com>; Karina Rosas <krosas@richardharrislaw.com>
Cc: Alma Duarte <aduarte@springelfink.com>
Subject: RE: Lowe v. Walmart/Securitas
Ian and Madison
Attached is a draft stipulation to dismiss. Please let us know if we can use your electronic signatures on it.
Thank you.
Chad D. Fuss
Attorney
(Image Omitted)
9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148
Tel: (702) 804-0706 | Fax: (702) 804-0798
From: Madison Aguirre <MAguirre@AlversonTaylor.com>
Sent: Thursday, March 16, 2023 8:40 AM
To: 'Ian Estrada' <lan@richardharrislaw.com>; Chad D. Fuss <cfuss@springelfink.com>: Nakesha
Duncan-Perez <riduncan@springelfink.com>; Karina Rosas <krosas@richardharrislaw.com>
Subject: RE: Lowe v. Walmart/Securitas
Good morning, That is accurate.
Thank you.
Madison Aguirre
Alverson Taylor & Sanders
702.384.7000 alversontaylor.com
From: Ian Estrada <lan@richardharrislaw.com>
Sent: Wednesday, March 15, 2023 7:06 PM
To: Chad D. Fuss <cfuss@springelfink.com>; Nakesha Duncan-Perez <nduncan@springelfink.com>: Madison Aguirre <MAguirre@AlversonTaylor.com>: Karina Rosas <krosas@richardharrislaw.com>
Subject: Lowe v. Walmart/Securitas
Chad and Madison, This is to confirm that both of your clients have agreed to a walk away. Mr. Lowe will dismiss your clients with prejudice and each party will cover their own fees and costs.
If this is not accurate, please let me know.
I will circulate a SAO to Dismiss shortly.
Thanks, Ian
This email has been scanned for spam and viruses. Click here to report this email as spam.
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