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Nikkei Global Inc. v. Co-Partner Consortium ("Partner-CO")
United States District Court, D. Nevada
March 29, 2019
Nikkei Global Inc., a California corporation, Plaintiff,
Co-Partner Consortium ("Partner-CO"), a Nevada general partnership associated in fact and as an enterprise per 18 USCA § 19613; Mr. Phillip Ziade, Nevada resident and copartner; Mr. Jude E. Nassar, an individual resident of Clark County, Nevada; Appleton Properties, LLC, a Nevada limited liability company; Z Leb Group, LLC, a Nevada limited liability company; Progressive Construction, Inc. a/k/a Growth Construction, a Nevada corporation; Growth Development, LLC a/k/a Growth Construction, a Nevada limited liability company; Vibrant Realty, LLC, a Nevada limited liability company; AJ Properties International, LLC, a/k/a AJ1, a Nevada limited liability company; AJ Properties International Series 2 LLC, a/k/a AJ2 a Nevada limited liability company; Growth Holdings, a Nevada corporation; Growth Luxury Homes, LLC, a/k/a GLH, a Nevada limited liability company; Growth Luxury Realty, LLC, a/k/a GLR, a Nevada limited liability company; Mr. Yoshimi Hirooka a resident of Japan or Singapore, doing business in Nevada; Mr. Yoshihiro Hirooka, a resident of Japan or Singapore doing business in Nevada; Hirooka Family Office, Ltd., a foreign organization doing business in Nevada, Defendants.
Richard I. Dreitzer James T. Tucker Wilson, Elser, Moskowitz,
Edelman & Dicker LLP Attorneys for Plaintiff, Nikkei
Richard Dreitzer Attorneys for Plaintiff Nikkei Global Inc.
A. Liebman Attorneys for the Ziade Defendants
AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF, NIKKEI GLOBAL,
INC. TO RESPONDTO DEFENDANTS PHILIPPE ZIADE, JUDE NASSAR,
APPLETON PROPERTIES, LLC, Z LEB GROUP, LLC, PROGRESSIVE
CONSTRUCTION, INC., GROWTH DEVELOPMENT, LLC, VIBRANT REALTY,
LLC, AJ PROPERTIES INTERNATIONAL, LLC, AJ PROPERTIES
INTERNATIONAL SERIES 2, LLC, GROWTH HOLDINGS, LLC, GROWTH
LUXURY HOMES, LLC, AND GROWTH LUXURY REALTY, LLC'S MOTION
TO DISMISS FIRST AMENDED COMPLAINT [ECF NO. 44] AND ZIADE
DEFENDANTS' REPLY IN SUPPORT OF SAME (FIRST
Nikkei Global Inc. (“Nikkei”), and Defendants
Philippe Ziade, Jude Nassar, Appleton Properties, LLC, Z Leb
Group, LLC, Progressive Construction, Inc., Growth
Development, LLC, Vibrant Realty, LLC, AJ Properties
International, LLC, AJ Properties International Series 2,
LLC, Growth Holdings, LLC, Growth Luxury Homes, LLC, and
Growth Luxury Realty, LLC (collectively, the “Ziade
Defendants”), by and through their respective counsel,
stipulate and agree as follows:
1. On October 18, 2018, Nikkei filed its Complaint [ECF No.
1] (the “Complaint”); 2. On November 19, 2018,
the Ziade Defendants accepted service of the Complaint.
3. On January 4, 2019, the Ziade Defendants filed their
Motion to Dismiss [ECF No. 23] and served Nikkei with the
4. On January 25, 2019, Nikkei filed a First Amended
Complaint [ECF 39], which is permitted one time as a matter
of course. See Fed. R. Civ. P. 15(a)(1)(B).
5. Due to the filing of the First Amended Complaint, Ziade
Defendants and Nikkei previously agreed, and the Court
ordered, a withdrawal of the pending Motion to Dismiss
because it had been mooted, in part, by Nikkei's filing
of the First Amended Complaint [ECF 40].
6. Ziade Defendants and Nikkei previously agreed, and the
Court ordered, that the Ziade Defendants shall have up to and
until March 8, 2019 to respond to the First Amended Complaint
7. On March 5, 2019, the Ziade Defendants requested a one
week extension to the prior deadline due to scheduling
issues, thereby extending their deadline for response to the
First Amended Complaint through March 15, 2019 [ECF 42, ECF
8. On March 15, 2019, the Ziade Defendants filed their Motion
to Dismiss First Amended Complaint and served Nikkei with the
same [ECF 44].
9. Because of scheduling conflicts and other litigation
commitments, Nikkei has respectfully requested that its date
for response to the Ziade Defendants' Motion to Dismiss
First Amended Complaint be extended from its current date of
March 29, 2019 through and including April 19, 2019. Counsel
for the Ziade Defendants have graciously agreed to this
10. Because of an upcoming trial for counsel of the Ziade
Defendants, they have requested that any Reply in support of
their Motion to Dismiss First Amended Complaint be filed on
or before May 15, 2019. Counsel ...