United States District Court, D. Nevada
HELPING HANDS WELLNESS CENTER, INC., a Nevada corporation, Plaintiff,
LUSINE DANAYAN, an individual; JACK DANAYAN, an individual, Defendants.
LEGA L & CONSU LTING, L LC Jared Kahn, Esq. Attorneys for
Plaintiff, Helping Hands Wellness Center, Inc.
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
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:
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.
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.
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.
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.
Defendants agree not to file a motion to disqualify
Plaintiff's counsel at any time during the agreed upon
stay through July 5, 2019.
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.
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
parties hereto further agree that this Stipulation may be
executed in one or more counterparts, each of which shall
constitute a duplicate original.
Court having reviewed the foregoing STIPULATION AND ORDER TO
STAY LITIGATION in the above-entitled matter and for good
cause appearing therefor:
IS SO ORDERED that the litigation in the
above-referenced matter be stayed through July 5, 2019 unless