Issues Raised Enforcing California Noncompete Clauses in Nevada Which are Against the Public Policy of California and Conflicts of Laws Issues

.        LEGAL ANALYSIS   A.        Frida Franco is not Subject to the Jurisdiction of the Nevada Courts,                         As She Had No Contacts with Nevada Sufficient to Confer Jurisdiction                         Over Her   Nevada’s long-arm statute, NRS 14.065, is broadly written to effectuate jurisdiction, “on any basis not inconsistent with the Constitution of this […]

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Motion to Transfer Nevada Federal Action to New York Per Forum Selection Clause

COME NOW Defendants VIS VIRES GROUP, INC., a New York Corporation; KBM WORLDWIDE, INC., a New York Corporation; ASHER ENTERPRISES, INC., a Delaware Corporation; SETH KRAMER; and CURT KRAMER (“Defendants”), by and through their undersigned counsel, ALBRIGHT, STODDARD, WARNICK & ALBRIGHT, and hereby file this Motion to Dismiss or in the Alternative to Transfer Venue […]

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Assignments of Bad Faith Claims, Stipulated Judgments and Covenants not to Execute

There are numerous cases involving an assignment of the insured’s bad faith claim against the insurer to the plaintiff, which include a stipulated judgment and covenant not to execute. Some insureds justifiably ask if they could potentially be liable for some type of collusion by the carrier. The following quotation from the California Supreme Court summarizes the general principles […]

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Domesticating Foreign Judgments in Nevada Under NRS 17.350. When to Record

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANT ALESSI’S MOTION TO REMOVE JUDGMENT LIEN Plaintiffs and Judgment Creditors 3405/3407 SLAUSON AVENUE, LLC, a California limited liability company; DAVID BEN ELIYAHU, an individual; ABRAHAM BEN ELIYAHU, an individual (“Judgment Creditors”) hereby oppose Judgment Debtor David A. Alessi’s Motion to Remove Judgment Lien […]

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The Discovery Rule, Statutes of Limitations and Surety Bond Contractual Limitation Clauses

SURETEC INSURANCE COMPANY’S OPPOSITION TO DEVELOPER’S SURETY AND INDEMNITY COMPANY’S MOTION FOR SUMMARY JUDGMENT; AND REQUEST FOR FURTHER DISCOVERY BEFORE RULING ON MOTION COMES NOW Defendant, Third-Party Plaintiff, SURETEC INSURANCE COMPANY (hereinafter “SureTec” or “Third-Party Plaintiff”), by and through its undersigned counsel of record, and opposes the Motion for Summary Judgment filed by Developer’s Surety […]

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Trip and Fall Complaint Against Texas Station for Defective Door

COMES NOW, Plaintiff EFFIE WILLIAMSl (hereinafter “Plaintiff”), by and through her attorneys of record, ALBRIGHT, STODDARD, WARNICK & ALBRIGHT, and as and for her Complaint against Defendant TEXAS STATION limited liability company, d/b/a TEXAS STATION HOTEL & CASINO (hereinafter “Defendant”), DOES I through X, and ROE CORPORATIONS I through XX, inclusive, alleges and avers as […]

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NRCP 62 Motion for Stay in Nevada Pending Appeal

G. MARK ALBRIGHT, ESQ. # 001394 D. CHRIS ALBRIGHT, ESQ. #004904 ALBRIGHT, STODDARD, WARNICK & ALBRIGHT 801 South Rancho Drive, Suite D-4 Las Vegas, Nevada 89106 Tel: (702) 384-7111 Fax: (702) 384-0605 gma@albrightstoddard.com dca@albrightstoddard.com Attorneys for Movants/Defendants IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF WASHOE […]

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Class Action for Concealment of Pacquiao Injury

RESPONSE AND PARTIAL JOINDER IN SUPPORT OF  MOTION FOR COORDINATION UNDER 28 U.S.C. § 1407 AND OPPOSITION TO PROPOSED TRANSFER VENUE   COME NOW Plaintiffs Robert Neidl, Victor Bobadilla, Victor Capo, John Assalian, Gerald F. Alessi, David Braunstein, Joseph Nick Constantino, and Howard Miller  (collectively, “Plaintiffs”), by and through counsel, and state as follows: I. […]

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Complaint Filed Against Pacquiao for Concealment of Shoulder Injury

G. Mark Albright William H. Stoddard, Jr. ALBRIGHT, STODDARD, WARNICK & ALBRIGHT 801 S. Rancho Drive, Suite D-4 Las Vegas, NV  89106 Telephone:  (702) 384-7111 Facsimile:  (702) 384-0605 Email: gma@albrightstoddard.com bstoddard@albrightstoddard.com     Laurence D. King (applying for admission pro hac vice) Linda M. Fong (applying for admission pro hac vice) Mario M. Choi  (applying […]

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Slip and Fall Sample Form Complaint in Las Vegas, Nevada

  DISTRICT COURT   CLARK COUNTY, NEVADA   MARY CARROLA, an individual, and ANDRES CARROLA, an individual   Plaintiffs,   vs.   WELLS FARGO BANK, NATIONAL ASSOCIATION, a national banking association;  and SCP 2006-C23-104 LLC; DOES I through X, and ROE CORPORATIONS I through XX, inclusive,   Defendants. CASE NO.: DEPT. NO.:       […]

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