Abbey Dental Center v. Consumer Opinion LLC

Filing 22

ORDER Granting 21 Stipulation to Stay Proceedings (8th Request). Action stayed for an additional 60 days. No further stipulations to extend the stay will be granted without a hearing to demonstrate a sufficient basis for the extension. Signed by Chief Judge Gloria M. Navarro on 10/17/2016. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:15-cv-02069-GMN-PAL Document 21 Filed 10/11/16 Page 1 of 4

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Marc J. Randazza (NV Bar No. 12265)
RANDAZZA LEGAL GROUP, PLLC
4035 S. El Capitan Way
Las Vegas, Nevada 89147
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant,
CONSUMER OPINION LLC

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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)
ABBEY DENTAL CENTER, INC., a Nevada ) Case No. 2:15-cv-02069-GMN-PAL
Corporation,
)
) STIPULATION AND (PROPOSED)
Plaintiff,
) ORDER TO STAY PROCEEDINGS
)
(8th Request)
vs.
)
)
CONSUMER OPINION LLC, a Nevada
)
Limited liability company; DOES 1-10; and
)
ROE ENTITIES 1-10, inclusive,
)
)
Defendant(s).
)
)

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Plaintiff, ABBEY DENTAL CENTER, INC., and Defendant, CONSUMER OPINION

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LLC, by and through their respective, undersigned counsel, do hereby stipulate and agree as

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follows:
1.

regards to the instant matter.
2.

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On January 6, 2016, the parties stipulated to stay the proceedings in this matter

for thirty (30) days, in order to allow the parties to facilitate settlement.
3.

The Court entered the parties’ stipulation as an Order on January 14, 2016.
[ECF No. 7]

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The aforesaid parties are currently actively engaged in settlement negotiations in

4.

The Court’s Order was due to expire on February 5, 2016.

5.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a second time on February 3, 2016.
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STIPULATION AND ORDER TO STAY PROCEEDINGS (8th Request)

Case 2:15-cv-02069-GMN-PAL Document 21 Filed 10/11/16 Page 2 of 4

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6.

The Court entered the parties’ second stipulation as an Order on February 9,

2016. [ECF No. 9]
7.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a third time on March 3, 2016.
8.

The Court entered the parties’ third stipulation as an Order on April 7, 2016.

[ECF No. 12]
9.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a fourth time on April 7, 2016.
10.

The Court entered the parties’ fourth stipulation as an Order on April 20, 2016.

[ECF No. 14]
11.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a fifth time on May 10, 2016.
12.

The Court entered the parties’ fifth stipulation as an Order on May 16, 2016.

[ECF No. 16]
13.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a sixth time on June 9, 2016.
14.

The Court entered the parties’ sixth stipulation as an Order on June 16, 2016.

[ECF No. 18].
15.

Due to continuing settlement discussion, the parties stipulated to stay the matter

for a seventh time on August 9, 2016.
16.

The Court entered the parties’ seventh stipulation as an Order on August 12,

2016. [ECF No. 20].
17.

The parties continue to engage in productive settlement discussion. As part of

their ongoing discussion, the parties have been negotiating language to be included in the

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parties’ settlement agreement. Coming to an agreement on the appropriate language for

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inclusion has caused delays in the parties’ negotiation efforts, as the conclusion will impact

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STIPULATION AND ORDER TO STAY PROCEEDINGS (8th Request)

Case 2:15-cv-02069-GMN-PAL Document 21 Filed 10/11/16 Page 3 of 4

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future litigation. Accordingly, in order to facilitate those efforts, as well as to minimize

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attorneys’ fees and other legal expenses, the parties believe that the present civil action should

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be stayed for an additional sixty (60) days.

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18.

Therefore, the parties agree that the Court may enter the following Order and

request that the Court do so accordingly:
a.

Except as otherwise provided below, this action shall be stayed for a

period of sixty (60) days from the date this stipulation is filed with the Court.
b.

The stay shall immediately terminate upon Plaintiff’s filing with the

Court, and serving upon Defendant, a notice that Defendant must file an answer to Plaintiff’s
complaint in this action or otherwise respond to same in accordance with the Federal Rules of
Civil Procedure and by no later than twenty-one (21) days after service of the notice.
c.

The parties stipulate that nothing in this delay shall be deemed to prejudice

Defendant’s right to file an Anti-SLAPP motion, under NRS 41.635 et. seq.
SO STIPULATED AND AGREED on this 11th day of October, 2016.
THE AMIN LAW GROUP NV, LTD.

RANDAZZA LEGAL GROUP, PLLC

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/s/ Ismail Amin
ISMAIL AMIN, ESQ.
Nevada Bar No. 9343
3753 Howard Hughes Parkway, Suite 200
Las Vegas, Nevada 89169
Telephone: [phone]

/s/ Marc J. Randazza
MARC J. RANDAZZA, ESQ.
Nevada Bar No. 12265
4035 South El Capitan Way
Las Vegas, Nevada 89147
Telephone: [phone]

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Attorney for Plaintiff

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Attorney for Defendant

IT IS SO ORDERED.
IT IS FURTHER ORDERED that no further stipulations to extend the stay will be granted
without a hearing to demonstrate a sufficient basis for the extension.
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DATED this ___ day of October, 2016.
_____________________________
Gloria M. Navarro, Chief Judge
United States District Court

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STIPULATION AND ORDER TO STAY PROCEEDINGS (8th Request)

Case 2:15-cv-02069-GMN-PAL Document 21 Filed 10/11/16 Page 4 of 4

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Case No. 2:15-cv-02069-GMN-PAL

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on October 11, 2016, I electronically filed the foregoing

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document with the Clerk of the Court using CM/ECF. I further certify that a true and correct

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copy of the foregoing document being served via transmission of Notices of Electronic Filing

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generated by CM/ECF.
Respectfully Submitted,
Employee,
Randazza Legal Group, PLLC

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STIPULATION AND ORDER TO STAY PROCEEDINGS (8th Request)