Russell Road Food and Beverage, LLC v. Galam et al

Filing 377

ORDER granting 374 Stipulation to Extend Time. Joint Proposed Discovery Plan and Scheduling Order due by 4/3/2018. Signed by Judge Richard F. Boulware, II on 3/28/2018. (Copies have been distributed pursuant to the NEF - MMM)

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BRUNO TARABICHI, CA State Bar No. 215129
[e-mail]
TMW LAW
4750 Almaden Expy 124-359
San Jose, California 95118
Telephone: [phone]
Facsmile: 408.715.6707
Pro Hac Vice
PUOY K. PREMSRIRUT, State Bar No. 7141
[e-mail]
PUOY K. PREMSRIRUT, ESQ. INC.
520 S. Fourth Street, Second Floor
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: 702.385.1752
Attorneys for Plaintiff
Russell Road Food and Beverage, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SOUTHERN DIVISION

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RUSSELL ROAD FOOD AND
BEVERAGE, LLC,
Plaintiff,
vs.

Case No. 2:13-cv-00776-RFB-NJK
STIPULATED REQUEST FOR ADDITIONAL
TIME TO SUBMIT PROPOSED JOINT
DISCOVERY AND SCHEDULING ORDER
Case Filed: May 2, 2013
Judge:
Honorable Richard F. Boulware

MIKE GALAM, et al.
Defendants.
MIKE GALAM, et al.,
Counterclaimants,
vs.
RUSSELL ROAD FOOD AND
BEVERAGE, LLC, et al.
Counterdefendant.

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STIPULATION
(CASE NO. 2:13-cv-00776-RFB-NJK)

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On February 28, 2018, this Court held a hearing on the following motions:
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Defendants Mike Galam, Victor Galam, Jacqueline Galam Barnes, Crazy

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Horse Too Gentlemen’s Club LLC, Rhino Bare Projects LLC, and Rhino

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Bare Projects 4824 LLC’s (the “Galam Defendants”) Motion for

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Reconsideration (ECF No. 336);

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•

Defendants Canico Capital Group, LLC and Industrial Road 2440-2497,

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LLC’s (the “Canico Defendants”) and Defendants Abraham Assil, George

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Eshaghian, West Best Capital Group, LLC, SN & GE, LLC, and Soleiman

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Nazarian’s (the “Assil Defendants”) Motion for Reconsideration (ECF No.

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337);
•

Defendants Djavid Hakakian, Morris Nejathaim, Hamed Yazdanpanah,

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Isaac Javdanfar, Kamran Samooha, Mehran Sadighpour, Sefox

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Investment, LLC, El Marino, LLC, Knotting Hill, LLC, IJ Properties, LLC, and

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S Double, LLC’s (the “Hakakian Defendants”) Motion for Reconsideration

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(ECF No. 339);

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•

Plaintiff Russell Road Food and Beverage, LLC’s (“Russell Road”) Cross-

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Motions for Summary Judgment against the Galam Defendants, Canico

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Defendants, Assil Defendants, and Hakakian Defendants (ECF Nos. 346,

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348, and 351); and

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•

Plaintiff Russell Road’s Motion for Preliminary Injunction (ECF No. 361).

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At the hearing, the Court took the motions under submission and ordered the parties to

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submit a proposed joint discovery and scheduling order.

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On March 12, 2018, the Court issued a Minute Order providing as follows:

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IT IS ORDERED that the parties shall submit a Joint
Proposed Discovery/Scheduling Order for this Court’s
consideration due by two weeks. The Scheduling Order
should include six to nine months of discovery with a motion
calendar as it relates to dispositive motions regarding the
issue of personal liability which can address the period of
infringement and damages. IT IS FURTHER ORDERED that
the parties are directed to electronically file in CM/ECF, a
joint letter for this Court’s consideration regarding any

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STIPULATION
(CASE NO. 2:13-cv-00776-RFB-NJK)

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disputed discovery issues. The parties are then directed to
notify the courtroom deputy as to scheduling a status
conference hearing.

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ECF No. 373. Pursuant to the Court’s Minute Order, the Joint Proposed Discovery and

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Scheduling Order was due on March 14, 2018.

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At present, the parties are unable to agree on the language of a Joint Proposed

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Discovery and Scheduling Order and are in the process of attempting to negotiate

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mutually acceptable language. The parties respectfully request additional time to

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submit the Joint Proposed Discovery and Scheduling Order.

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The parties propose that they be given until April 3, 2018 to submit a Joint

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Proposed Discovery and Scheduling Order and that, if the parties are unable to reach

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agreement on a Joint Proposed Discovery and Scheduling Order by April 3, 2018, the

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parties shall each submit their own proposed Discovery and Scheduling Order by April

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6, 2018 for the Court’s consideration.

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IT IS SO STIPULATED

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Dated: March 26, 2018

Respectfully submitted,
TMW LAW

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By

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/s/ Bruno Tarabichi
Bruno Tarabichi
Attorneys for Plaintiff
Russell Road Food and Beverage, LLC

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STIPULATION
(CASE NO. 2:13-cv-00776-RFB-NJK)

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Dated: March 26, 2018

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Respectfully submitted,
LAMBROSE BROWN PLLC

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By

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Dated: March 26, 2018

/s/ William Brown
William Brown
Attorneys for Defendants Mike Galam,
Crazy Horse Too Gentlemen’s Club LLC,
Victor Galam, Jacqueline Galam Barnes,
Rhino Bare Projects LLC, and Rhino Bare
Projects 4824 LLC

Respectfully submitted,
AKERMAN LLP

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By

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/s/ Ariel E. Stern
Ariel E. Stern
Attorneys for Defendants Canico Capital
Group, LLC, Industrial Road 2440-2497,
LLC, Abraham Assil, George Eshaghian,
West Best Capital Group, LLC, SN & GE,
LLC, and Soleiman Nazarian

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Dated: March 26, 2018

Respectfully submitted,
LEBEDEV, MICHAEL & HELMI

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By

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/s/ Gennady L. Lebedev
Gennady L. Lebedev
Attorneys for Defendants Djavid
Hakakian, Morris Nejathaim, Hamed
Yazdanpanah, Isaac Javdanfar, Kamran
Samooha, Mehran Sadighpour, Sefox
Investment, LLC, El Marino, LLC,
Knotting Hill, LLC, IJ Properties, LLC, and
S Double, LLC

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STIPULATION
(CASE NO. 2:13-cv-00776-RFB-NJK)

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IT IS SO ORDERED:

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HON. RICHARD F. BOULWARE
UNITED STATES DISTRICT JUDGE

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DATED: March 28, 2018.

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STIPULATION
(CASE NO. 2:13-cv-00776-RFB-NJK)