1 OFFR , Esq. 2 Nevada Bar No.: 6592 , LTD.
3 Suite 201 , NV 89052 4 Tele: Fax: 5 Attorneys for Plaintiff, 6 7 8 9 , 10 11 vs. 12 , 13 14 15 16 17 18 vs. , Defendant. _________________________________________ , Counterclaimant, Plaintiff, DISTRICT COURT CLARK COUNTY, NEVADA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: Dept No.:
defendant. 19 _________________________________________ 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 20 21 22 23 24 TO:
DEFENDANTS OFFER OF JUDGMENT TO PLAINTIFF
Plaintiff ______________ and their counsel _________. Pursuant to the provisions of N.R.C.P. 68 and NRS 17.115, Defendant, _________, by and
2526 through his attorney of record, _________, hereby offers to allow Plaintiff, ________, to take judgment against Defendant, ______, in this action in the total sum of ____________ DOLLARS
004.086/Pleadings/000 CAPTION
1 AND NO CENTS ($_________,000.00), which sum includes all attorneys fees, costs and interest and 2 resolves all claims by Plaintiff against Defendant. 3 Therefore, acceptance of this offer will require the Defendant to pay a total sum of
4 ________________ DOLLARS AND NO CENTS ($___________,000.00) and nothing more (Sum 5 Total). This Offer of Judgment is made for the purposes specified in Rule 68 of the Nevada Rules of 6 Civil Procedure and NRS 17.115, and is not to be construed as an admission of any kind whatsoever 7 and this matter shall be considered a compromise settlement. Furthermore pursuant to request by 8 Defendant, should Plaintiff accept this Offer of Judgment, Plaintiff agrees they will dismiss their 9 Complaint against Defendant instead of entering judgment and Defendant agrees to pay the Sum Total 10 within a reasonable time, as is Defendants option to request pursuant to NRS 17.115(2)(a)(1) and 11 N.R.C.P. 68(d). 12 13 14 15 TO: 16 TO: 17 Defendant/Counterclaimant, ANA CHIU; and, D. JASON FERRIS, ESQ., Counsel for Defendant/Counterclaimant: Pursuant to the provisions of N.R.C.P. 68 and NRS 17.115, Plaintiff/Counterdefendant, PAUL
18 J. RAUHUT, by and through his attorney of record, HARRIS MERRITT CHAPMAN, LTD. hereby 19 offers to allow Plaintiff/Counterdefendant, PAUL J. RAUHUT, to take judgment against 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 23 Defendant/Counterclaimant. 24 Therefore, acceptance of this offer will require the Defendant/Counterclaimant, to pay a total 20 Defendant/Counterclaimant, ANA CHIU, in this action collectively in the total sum of THIRTY-FIVE 21 THOUSAND DOLLARS AND NO CENTS ($35,000.00), which sum includes all attorneys fees and 22 costs and resolves all claims by Plaintiff/Counterdefendant and all counterclaims by
2526 of THIRTY-FIVE THOUSAND DOLLARS AND NO CENTS ($35,000.00) and nothing more. This Offer of Judgment is made for the purposes specified in Rule 68 of the Nevada Rules of Civil
004.086/Pleadings/000 CAPTION
1 Procedure and NRS 17.115, and is not to be construed as an admission of any kind whatsoever. 2 Furthermore, should Defendant accept this Offer of Judgment, Counterclaimant will dismiss their 3 Counterclaims against Plaintiff/Counterdefendants and upon request Plaintiff/Counterdefendant will 4 dismiss their claims against Defendant/Counterclaimant instead of entering judgment, as is their option 5 to request pursuant to NRS 17.115(2)(a)(1) and N.R.C.P. 68(d). 6 7 8 9 10 11 12 13 14 15 16 17 18 19 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 20 21 22 23 24 2526 __________________________________ Scott Chapman, Esq. 866 Seven Hills Dr., Suite 201 Henderson, NV 89052 (702) 492-0052 Attorneys for Plaintiff, PAUL J. RAUHUT Moreover, Defendant and Counterclaimant are represented by the same counsel in this case. DATED this _____ day of April, 2012. HARRIS MERRITT CHAPMAN, LTD.
004.086/Pleadings/000 CAPTION
1 2
CERTIFICATE OF SERVICE
I hereby certify that on the ______ day of __________, 2010 service of the foregoing document, entitled PAUL J. RAUHUTS OFFER OF JUDGMENT TO ANA CHIU 3 , was made by [ ] hand delivery / [ ] facsimile transmission / [ ] regular mail, pursuant to NRCP 5(b) and EJDCR 7.26, [ ] by personal delivery of the document to those listed below / [ ] by faxing 4 the document to the fax numbers listed below / [ ] by depositing the document for mailing, in a sealed envelope, U.S. postage prepaid, in Clark County, Nevada, to those listed below. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 20 21 22 23 24 2526 ____________________________________________ An employee of HARRIS MERRITT CHAPMAN, LTD. D. Jason Ferris, Esq. ROBINSON & WOOD, INC. 5556 S. Fort Apache Road, #100 Las Vegas, Nevada 89148 Attorneys for Defendant (702) 363-5100; Fax (702) 363-5101
004.086/Pleadings/000 CAPTION
