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Helping Hands Wellness Center, Inc. v. Danayan

United States District Court, D. Nevada

June 17, 2019

HELPING HANDS WELLNESS CENTER, INC., a Nevada corporation, Plaintiff,
v.
LUSINE DANAYAN, an individual; JACK DANAYAN, an individual, Defendants.

          JK LEGA L & CONSU LTING, L LC Jared Kahn, Esq. Attorneys for Plaintiff, Helping Hands Wellness Center, Inc.

          W OOD SMITH HENNING & BERMA N, L LP Joel D. Odou, Esq., Christina M. Mamer, Esq., Nick F. Adams, Esq. Attorneys for Defendants, Lusine Danayan and Jack Danayan

          STIPULATION AND ORDER TO STAY LITIGATION

         LUSINE DANAYAN and JACK DANAYAN (hereinafter "Defendants") and HELPING HANDS WELLNESS CENTER, INC., a Nevada Corporation (hereinafter "Plaintiff") (collectively, "the Parties") by and through their respective counsel, hereby stipulate and agree as follows:

         1. That the litigation in the entitled matter, Helping Hands Wellness Center, Inc. v. Lusine Danayan, et al., No. 2:19-cv-00881-JCM-NJK ("the Action") shall be stayed through July 5, 2019 to allow the parties further time to attempt to resolve the instant matter and not incur unnecessary litigation fees and costs.

         2. That Defendants' opposition to Plaintiff's Emergency Motion to Remand to State Court [ECF No. 5], which is currently due on June 11, 2019, will now be due on Monday, July 8, 2019 in the event the parties do not file a notice of settlement on or before July 5, 2019 or seek a further stay of the instant matter. Plaintiff's reply brief shall be due on or before July 10, 2019.

         3. That Defendants' Opposition to Motion for Preliminary Injunction [ECF No.6], which is currently due on June 17, 2019, will now be due on or before Monday, July 15, 2019 in the event the parties do not file a notice of settlement on or before July 5, 2019 or seek a further stay of the instant matter. Plaintiff's reply brief shall be due on or before July 20, 2019.

         4. That Defendants' responsive pleading to Plaintiff's Complaint, which is currently due on or before June 13, 2019, will now be due on Monday, July 15, 2019 unless the parties seek a further stay of the matter.

         5. Defendants agree not to file a motion to disqualify Plaintiff's counsel at any time during the agreed upon stay through July 5, 2019.

         6. Defendants shall submit a timely and adequate resolution proposal to Plaintiff no later than Friday, June 14, 2019 at 5:00 p.m. In the event that Defendants fail to timely submit an adequate resolution proposal, Plaintiff can seek to lift the stay prior to July 5, 2019.

         7. The Parties agree that the instant Stipulation and Order for Stay of Litigation shall not be construed as a waiver of any claims. Instead, the Stipulation and Order is merely a vehicle for the parties to attempt to resolve the instant matter.

         The parties hereto further agree that this Stipulation may be executed in one or more counterparts, each of which shall constitute a duplicate original.

         ORDER

         The Court having reviewed the foregoing STIPULATION AND ORDER TO STAY LITIGATION in the above-entitled matter and for good cause appearing therefor:

         IT IS SO ORDERED that the litigation in the above-referenced matter be stayed through July 5, 2019 unless ...


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