`
`MICHAEL M. EDWARDS, ESQ.
`Nevada Bar No. 6281
`NICHOLAS L. HAMILTON, ESQ.
`Nevada Bar No. 10893
`MESSNER REEVES LLP
`8945 West Russell Road, Suite 300
`Las Vegas, Nevada 89148
`Telephone: (702) 363-5100
`Facsimile: (702) 363-5101
`E-Mail: medwards@messner.com
`E-Mail: nhamilton@messner.com
`Attorneys for Defendant,
`JAMES CHOW
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NEVADA
`
`BALUMA, S.A., d/b/a Enjoy Punta del
`Este & Casino,
`
`Case No. 2:20−cv−01749−JCM−EJY
`
`v.
`
`JAMES CHOW,
`
`Plaintiff,
`
`Defendant.
`
`STIPULATION AND ORDER TO REMAND
`MATTER TO THE COURTS OF THE
`EIGHTH JUDICIAL DISTRICT OF
`NEVADA
`
`COMES NOW Defendant JAMES CHOW, by and through his attorneys of record, the
`
`law firm MESSNER REEVES, LLP, Plaintiffs BALUMA, S.A., d/b/a Enjoy Punta del Este &
`
`Casino, by and though its attorney of record Christopher R. Miltenberger, Esq. of GREENBERG
`
`TRAURIG, LLP, hereby stipulate and agree to remand this matter State Court.
`
`This matter was removed from the Eighth District Court of Nevada where it was pending
`
`under Case No. A-20-817919-C.
`
`Defendant removed this matter under 28 U.S.C. §§ 1332(a)(1), 1441, and 1446.
`
`Plaintiff has alleged claims for breach of contract, breach of the covenant of good faith and
`
`fair dealing, and unjust enrichment against Defendant.
`
`Upon Defendant’s further review of Plaintiff’s Complaint, it is apparent that diversity
`
`jurisdiction does not exist as the principal amount in controversy in Plaintiff’s Complaint, exclusive
`
`{04409268 / 1}
`
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`Case 2:20-cv-01749-JCM-EJY Document 4 Filed 10/07/20 Page 2 of 2
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`of interest and costs, does not exceed the amount in controversy required by 28 U.S.C. § 1332(a).
`
`In light of the foregoing, the parties hereby stipulate and agree to remand this matter to the
`
`Eighth District Court of Nevada.
`
`Defendant reserves his objections concerning Plaintiff’s selection of the forum of this matter.
`
`DATED this 5th day of October 2020.
`
`DATED this 5th day of October 2020.
`
`MESSNER REEVES LLP
`
`GREENBERG TRAURIG, LLP
`
`/s/ Michael Edwards____________________
`Michael M. Edwards, Esq.
`Nevada Bar No. 6281
`Nick L. Hamilton, Esq.
`Nevada Bar No. 10893
`8945 W. Russell Rd., Ste. 300
`Las Vegas, Nevada 89148
`Attorneys for Defendant, ALLEN CHANG
`
`/s/ Christopher R. Miltenberger___________
`Christopher R. Miltenberger, Esq.
`Nevada Bar No. 10153
`Christian T. Spaulding, Esq.
`Nevada Bar No. 14277
`10845 Griffith Peak Drive, Suite 600
`Las Vegas, NV 89135
`Attorneys for Plaintiff
`Baluma, S.A., d/b/a Enjoy Punta del Este &
`Casino
`
`IT IS SO ORDERED.
`
`October
`7th
`DATED this _____ day of _________________, 2020.
`
`
`____________________________
`UNITED STATES DISTRICT COURT JUDGE
`
`{04409268 / 1}
`
`- 2 -
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`STIPULATION TO REMANDACTIVE 52899152v1
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