Sinanyan et al v. Luxury Suites International, LLC et al

Filing 104

ORDER re 103 Stipulation. IT IS HEREBY ORDERED that all pending deadlines relating to Plaintiffs and Defendant Luxury Suites International, LLC ("LSI") are stayed pending mediation. IT IS FURTHER ORDERED that a Status Report is due by 9/19/2016. IT IS FURTHER ORDERED that 99 Motion for Partial Summary Judgment is DENIED without prejudice. Signed by Chief Judge Gloria M. Navarro on 7/20/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-00225-GMN-VCF Document 103 Filed 07/15/16 Page 1 of 4

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DON SPRINGMEYER, ESQ.
Nevada Bar No. 1021
JUSTIN JONES, ESQ.
Nevada Bar No. 8519
ROYI MOAS, ESQ.
Nevada Bar No. 10686
WOLF, RIFKIN, SHAPIRO,
SCHULMAN & RABKIN, LLP
3556 E. Russell Road, Second Floor
Las Vegas, Nevada 89120
[phone]/Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
ALICE SINANYAN AND JAMES KOURY

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J. SCOTT BURRIS
Nevada Bar No. 10529
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
300 South 4th Street, 11th Floor
Las Vegas, NV 89101
[phone]; FAX [phone]
[e-mail]
Attorneys for Defendant
LUXURY SUITES INTERNATIONAL, LLC

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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ALICE SINANYAN, an individual; JAMES
KOURY, an individual and trustee of the
Koury Family Trust; and SEHAK TUNA, an
individual, on behalf of themselves and others
similarly situated,

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STIPULATION AND [PROPOSED]
ORDER TO STAY CASE DEADLINES AS
TO PLAINTIFFS AND DEFENDANT
LUXURY SUITES INTERNATIONAL,
LLC ONLY

Plaintiffs,
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vs.
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Case No. 2:15-CV-00225-GMN-VCF

LUXURY SUITES INTERNATIONAL, LLC,
a Nevada limited liability company; RE/MAX
PROPERTIES, LLC, a Nevada limited
liability company; JETLIVING HOTELS,
LLC, a Nevada limited liability company; JAB
AFFILIATES, LLC, a Nevada limited liability
company; and DOES 1 through 100, inclusive,

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Defendants.
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-1Stipulation and Order

Case 2:15-cv-00225-GMN-VCF Document 103 Filed 07/15/16 Page 2 of 4

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PLEASE TAKE NOTICE, that it is hereby stipulated and requested between Plaintiffs

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and Defendant Luxury Suites International, LLC (“LSI”), a Nevada limited liability company, by

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and through counsel of record, that the Court order a stay of all proceedings in this action and all

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currently-pending deadlines relating to Plaintiffs and Defendant Luxury Suites International,

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LLC (“LSI” and collectively with Plaintiffs, the “Parties”).

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The Parties have diligently pursued discovery in this matter and have several expert and

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lay witness depositions scheduled in the next two weeks prior to the discovery cutoff date. The

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Parties also have upcoming briefing due relating to LSI’s Motion for Partial Summary Judgment

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(ECF No. 99). Counsel for the Parties have discussed the benefits of engaging in a second

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session of mediation with Judge Philip Pro (Ret.) before significant additional resources and time

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are expended on discovery and motion practice. As a result, the Parties have agreed to suspend

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litigation efforts and direct their energies and resources instead to mediate in good faith in an

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effort to reach a settlement of the remaining claims in this action.

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The Parties are considering and expect to confirm a mediation date with Judge Pro in late

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August. The Parties request the Court to order an immediate stay of all deadlines relating to the

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Parties. Any deadlines or pending motions relating to other defendants in this matter shall not be

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affected by this stipulation. Should efforts to mediate fail, the Parties will notify the Court no

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later than one week after the mediation and request a reasonable reset of the various deadlines.

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DATED this 15th day of July, 2016.
WOLF, RIFKIN, SHAPIRO,
SCHULMAN & RABKIN, LLP

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By: /s/ Justin Jones
DON SPRINGMEYER, ESQ.
Nevada Bar No. 1021
JUSTIN JONES, ESQ.
Nevada Bar No. 8519
3556 E. Russell Road, Second Floor
Las Vegas, Nevada 89120
Attorneys for Plaintiffs Alice Sinanyan
and James Koury

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-2Stipulation and Order

Case 2:15-cv-00225-GMN-VCF Document 103 Filed 07/15/16 Page 3 of 4

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DATED this 15th day of July, 2016.
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
By: /s/ J. Scott Burris
J. SCOTT BURRIS, ESQ.
Nevada Bar No. 10529
300 South 4th Street, 11th Floor
Las Vegas, NV 89101
Attorneys for Defendant Luxury Suites
International, LLC

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ORDER
IT IS HEREBY ORDERED that all pending deadlines relating to Plaintiffs and
Defendant Luxury Suites International, LLC ("LSI") are stayed pending mediation.
IT IS FURTHER ORDERED that Plaintiffs and LSI shall file a joint status report
informing the Court of the status of mediation every 60 days, beginning on September 19, 2016.
IT IS FURTHER ORDERED that LSI's Motion for Partial Summary Judgment (ECF
No. 99) is DENIED without prejudice.

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______________________________________
HONORABLE UNITED STATES JUDGE

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DATED this ___ day of July, 2016.

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-3Stipulation and Order

Case 2:15-cv-00225-GMN-VCF Document 103 Filed 07/15/16 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on this 15th day of July, 2016, a true and correct copy of

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STIPULATION AND [PROPOSED] ORDER TO STAY CASE DEADLINES AS TO

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PLAINTIFFS AND DEFENDANT LUXURY SUITES INTERNATIONAL, LLC ONLY

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was served via the United States District Court CM/ECF system on all Parties or persons

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requiring notice.

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By: /s/ Dannielle Fresquez
Dannielle Fresquez, an Employee of
WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP

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-4Stipulation and Order