Estrella Franchising Corp. v. American Access Agency of Nevada, LLC et al

Filing 14

ORDER Granting 13 Stipulation to Extend Deadline to Response to 7 Motion for Preliminary Injunction. Responses due by 4/12/2018. Replies due by 4/19/2018. Signed by Chief Judge Gloria M. Navarro on 3/27/2018. (Copies have been distributed pursuant to the NEF - ASB)

Steve Morris, Nevada Bar No. 1543
Jean-Paul Hendricks, Nevada Bar No. 10079
MORRIS LAW GROUP
411 E. Bonneville Ave., Ste. 360
Las Vegas, Nevada 89101
Telephone: [phone]
[e-mail]
[e-mail]

MORRIS LAW GROUP

Victoria E. Brieant (Pro Hac Vice forthcoming)
LAW OFFICE OF VICTORIA E. BRIEANT, P.A.
4000 Ponce de Leon Blvd., Ste. 470
Coral Gables, Florida 33146
Telephone: [phone]
[e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
ESTRELLA FRANCHISING CORP., )
a Florida corporation,
)
)
Plaintiff,
)
)
v.
)
)
)
AMERICAN ACCESS AGENCY OF )
NEVADA, LLC, a Nevada limited )
liability company, its officer DON )
TURNER, an Individual, and )
AMERICAN ACCESS CASUALTY )
COMPANY, an Illinois corporation, )
)
)
Defendants.
)

)
Case No. 2:18-cv-00433
STIPULATION TO EXTEND
DEADLINE TO RESPOND TO
MOTION FOR PRELIMINARY
INJUNCTION

Pursuant to LR IA 6-1, plaintiff Estrella Franchising Corp. and
defendants American Access Agency of Nevada, LLC, Don Turner, and
American Access Casualty Company (collectively "Defendants") hereby

stipulate to extend the deadline to respond to plaintiff’s Motion for
Preliminary Injunction. In support of this request, the parties state as
follows:
The complaint in this action, ECF No. 4, was filed on March 9,
2018, thereafter plaintiff filed a Motion for Preliminary Injunction, ECF No.
7, on March 12, 2018. On March 19, 2018, counsel for Defendants contacted
counsel for plaintiff and indicated a willingness and desire to settle the
stated claims without litigation. Since that time, counsel for the parties have
initiated settlement discussions and it appears that a mutually agreeable

MORRIS LAW GROUP

global resolution of this action may be possible. To that end, the parties
stipulate to extend the deadline to respond to the Motion for Preliminary
Injunction two weeks (14 days) to allow settlement discussions to continue.
In the event that settlement is not reached, Defendants expressly reserve the
right to respond to the Complaint in any manner permitted by the Federal
Rules of Civil Procedure.
The response to the Motion for Preliminary Injunction is
currently due March 29, 2018. The reply in support of the motion for
preliminary injunction is currently due April 5, 2018. The parties hereby
stipulate that the deadline to respond to the Motion for Preliminary
Injunction shall be extended to April 12, 2018, and any reply in support of
the Motion for Preliminary Injunction shall be due on April 19, 2018. This
represents an extension of 14 days, is the first request to extend any deadline
in this case, and is made expressly for purposes of settlement.

2

Dated: March 23, 2018

MORRIS LAW GROUP

CLINGEN CALLOW & MCCLEAN,
LLC

By: /s/ Jean-Paul Hendricks
Steve Morris, Bar No. 1543
Jean-Paul Hendricks, Bar No. 10079
411 E. Bonneville Ave., Ste. 360
Las Vegas, Nevada 89101
Telephone: [phone]
[e-mail]
[e-mail]

MORRIS LAW GROUP

Dated: March 23, 2018

By: /s/ Kenneth J. Vanko
Kenneth J. Vanko
Illinois Bar No. 6244048
2300 Cabot Drive, Suite 500
Lisle, Illinois 60352
Telephone: [phone]
[e-mail]
Attorney for Defendants
American Access Agency of
Nevada, LLC, Don Turner, and
American Access Casualty
Company

LAW OFFICE OF VICTORIA E.
BRIEANT
Victoria E. Brieant (Pro Hac Vice
forthcoming)
4000 Ponce de Leon Blvd., #470
Coral Gables, FL 33146
Telephone: [phone]
[e-mail]
Attorneys for Plaintiff
Estrella Franchising Corp.

ORDER
The parties' stipulation is so ordered.

United States District Court Judge
DATED:

3

March 27, 2018

Submitted by:
MORRIS LAW GROUP
By: /s/ Jean-Paul Hendricks
Steve Morris, Bar No. 1543
Jean-Paul Hendricks, Bar No. 10079
411 E. Bonneville Ave., Ste. 360
Las Vegas, Nevada 89101
Telephone: [phone]
[e-mail]
[e-mail]

MORRIS LAW GROUP

Attorneys for Plaintiff
Estrella Franchising Corp.

4

5

MORRIS LAW GROUP