`
`
`
`CLARK HILL PLLC
`PAOLA M. ARMENI
`Nevada Bar No. 8357
`Email: parmeni@clarkhill.com
`GIA N. MARINA
`Nevada Bar No. 15276
`Email: gmarina@clarkhill.com
`1700 S. Pavilion Center Dr., Ste. 500
`Las Vegas, Nevada 89135
`Tel: (702) 862-8300
`Fax: (702) 778-9709
`Attorneys for Plaintiffs, Perez Family
`
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`
`CASE NO.: 2:15-cv-01572-APG-DJA
`
`
`
`
`
`STIPULATION AND ORDER FOR
`DISMISSAL WITH PREJUDICE
`
`
`
` Plaintiffs,
`
`VICTOR PEREZ, as Special Administrator of
`the Estate of CARLOS PEREZ, deceased;
`VICTOR PEREZ, as the Guardia Ad Litem for
`S.E.P., a minor; VICTOR PEREZ, as the
`Guardian Ad Litem for A.I.P., a minor,
`
`
`vs.
`
`STATE OF NEVADA, ex.rel. NEVADA
`DEPARTMENT OF CORRECTIONS;
`DIRECTOR GREG COX, individually;
`WARDEN DWIGHT NEVEN, individually;
`ASSISTANT WARDEN TIMOTHY FILSON,
`individually; COT. RAMOS, individually;
`LIEUTENANT OLIVER, individually;
`CORRECTIONS OFFICER CASTRO,
`individually; CORRECTIONS OFFICER
`SMITH, individually; and DOES I-X, inclusive;
`and ROES I-X, inclusive,
`
` Defendants.
`
`
`
`COMES NOW, Plaintiffs Victor Perez, as Special Administrator of the Estate of Carlos
`
`Perez, deceased, Victor Perez as Guardian Ad Litem for S.E.P. and A.I.P., by and through his
`
`counsel, Paola M. Armeni, Esq., and Gia N. Marina, Esq., of the law firm of Clark Hill, Defendant
`
`Raynaldo Ramos, by and through his counsel, Robert W. Freeman, Jr. Esq., of the law firm of
`
`Lewis Brisbois Bisgaard & Smith, LLP, Defendants, State of Nevada ex rel Nevada Department
`
`of Corrections, James Greg Cox, Timothy Filson, Dwight W. Neven and Ronald Oliver, by and
`
`through their counsel, Kiel Ireland, Esq. of the Attorney General’s Office, Defendant Isaiah Smith,
`
`by and through his counsel of record Jeffrey F. Barr, Esq. of the law firm of Ashcraft and Barr
`
`LLP, and Defendant Jeff Castro, by and through his counsel, Craig Anderson, Esq., of the law firm
`
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`Case 2:15-cv-01572-APG-DJA Document 276 Filed 11/28/23 Page 2 of 2
`
`of Marquis Aurbach, hereby agree and stipulate to the dismissal of Plaintiffs’ claims against
`
`Defendants with prejudice. The parties have met the conditions of settlement and each party will
`
`bear their own attorney’s fees and cost.
`
`APPROVED AS TO FORM AND CONTENT.
`
`Respectfully submitted this 27th day of November 2023.
`
`CLARK HILL, PLLC
`/s/ Paola M. Armeni, Esq.
`PAOLA M. ARMENI
`Nevada Bar No. 8357
`GIA N. MARINA
`Nevada Bar No. 15276
`1700 S. Pavilion Center Dr. Ste., #500
`Las Vegas, Nevada 89135
`Attorneys for Plaintiffs, Perez Family
`
`MARQUIS AURBACH
`/s/ Craig R. Anderson, Esq.
`Craig R. Anderson, Esq.
`Nevada Bar No. 6882
`10001 Park Run Drive
`Las Vegas, NV 89145
`Attorneys for Defendant Jeffrey Castro
`
`ASHCRAFT AND BARR
`/s/ Jeffrey F. Barr, Esq.
`Jeffrey F. Barr, Esq.
`Nevada Bar No. 7269
`8275 s. Eastern Ave., Suite 200
`Las Vegas, NV 89123
`Attorneys for Defendant Isaiah Smith
`
`LEWIS BRISBOIS BISGAARD &
`SMITH LLP
`/s/ Robert W. Freeman, Jr., Esq.
`Robert W Freeman, Jr., Esq.
`Nevada Bar No. 3062
`6385 S. Rainbow Blvd., Ste. 600
`Las Vegas, NV 89118
`Attorneys for Defendant Raynaldo Ramos
`
`OFFICE OF THE ATTORNEY
`GENERAL
`/s/ Kiel Ireland, Esq.
`Kiel Ireland, Esq.
`Nevada Bar No. 15368
`100 N Carson St
`Carson City, NV 89701
`Attorneys for Defendants, State of Nevada,
`Dwight W. Neven, James Greg Cox
`Ronald Oliver, Timothy Filson
`
`ORDER
`
`IT IS SO ORDERED:
`
`DATED: November 28, 2023
`
`ANDREW P. GORDON
`UNITED STATES DISTRICT JUDGE
`
`CLARKHILL\J2020\392971\274545569.v1-11/20/23
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