CMC HOLDINGS, LLC, a Nevada limited liability company d/b/a Chinook Motor Homes v. NEWMAR CORPORATION, an Indiana corporation
Case No. 2:25-cv-00963-JCM-EJY
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
January 21, 2026
Document 17 Filed 01/21/26
NV Bar No.: 12145
WOMBLE BOND DICKINSON (US) LLP
8488 Rozita Lee Ave., Suite 400
Las Vegas, NV 89113
Tele: 702-949-8200
E-mail: Meng.Zhong@wbd-us.com
Attorneys for Newmar Corporation
JOINT MOTION AND STIPULATION TO STAY CASE DUE TO SETTLEMENT
(FIRST REQUEST)
Plaintiff CMC Holdings, LLC (“CMC” or “Plaintiff“) and Defendant Newmar Corporation (“Newmar” or “Defendant“) (collectively, the “Parties“), respectfully submit this Joint Motion and Stipulation to Stay Case due to Settlement and state as follows:
BACKGROUND AND STATUS OF SETTLEMENT NEGOTIATIONS
The Parties have utilized the time afforded by the Court‘s prior extensions to engage in meaningful settlement negotiations. Those efforts have proven productive: the Parties have now reached agreement on the principal terms necessary to resolve this matter in its entirety. The Parties require additional time only to memorialize those terms in a comprehensive written settlement agreement and to execute that agreement.
/ / /
/ / /
/ / /
Because the Parties have substantively resolved their dispute, continued litigation activity is unnecessary. The Parties therefore jointly move to stay all proceedings in this case for a period of 45 days, up to and including March 5, 2026, to permit the Parties to focus their resources and efforts on finalizing, executing, and memorializing a comprehensive settlement agreement and thereafter submitting a joint stipulation of dismissal.
GOOD CAUSE EXISTS FOR A STAY
Good cause supports this request. A brief stay at this juncture will promote judicial economy and the efficient administration of justice. Because the Parties have reached agreement on the material terms of settlement, a stay will obviate the need for Defendant to file an answer to the Complaint, eliminate the need for the Court to conduct case management proceedings, and avoid motion practice and other litigation activity that would otherwise consume the resources of the Court and the Parties over the coming months. In short, a 45-day stay now will conserve significant judicial and party resources that would otherwise be expended on litigation that the Parties have agreed to resolve.
This motion is made in good faith and is not brought for the purpose of delay.
CONCLUSION
For the foregoing reasons, the Parties respectfully request that the Court enter an order staying all proceedings in this case through and including March 5, 2026. In the event that the
Dated: January 14, 2026.
DICKINSON WRIGHT PLLC
/s/ John L. Krieger
John L. Krieger, Esq.
Nevada Bar No. 6023
Gregory P. Gemignani, Esq.
Nevada Bar No. 7346
Jordan M. Marchello, Esq.
Nevada Bar No. 16926
3883 Howard Hughes Pkwy, Suite 800
Las Vegas, Nevada 89169-0965
Tel: 702-550-4400
Attorneys for Plaintiff CMC Holdings, LLC
WOMBLE BOND DICKINSON (US) LLP
/s/ Meng Zhong
Meng Zhong
Nevada Bar No. 12145
8488 Rozita Lee Ave., Suite 400
Las Vegas, NV 89113
Tel: 702-949-8200
Heather Kliebenstein (pro hac vice forthcoming)
Andrew S. Ehard (pro hac vice forthcoming)
MERCHANT & GOULD P.C.
150 South Fifth Street, Suite 2200
Minneapolis, Minnesota 55402
Tel: 612-371-5228
Attorneys for Defendant Newmar Corporation
ORDER
IT IS SO ORDERED.
UNITED STATES DISTRICT JUDGE
Dated: January 21, 2026