Pricestack, Inc. v. Heart of Sun, LLC

1 || Michael J. McCue Nevada Bar No. 6055 2 || LEWIS ROCA ROTHGERBER CHRISTIE LLP 3993 Howard Hughes Parkway, Suite 600 Las Vegas, NV 89169 T: 702-949-8200 4 || E-mail: mmccue@LewisRoca.com 5 || Attorneys for Pricestack, Inc. dba Preflect [6] 7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA [8] 9|| PRICESTACK, INC., a Delaware Case No.: 2:22-cv-01447-APG-DJA corporation, [10] Plaintiff, 11 STIPULATION TO EXTEND TEMPORARY V. RESTRAINING ORDER AND BRIEFING ON 12 PRELIMINARY INJUNCTION HEART OF SUN, LLC, a Florida 131) limited liability company; SOPHIA LIMA, an individual; and NICHOLAS © RUS, an individual, (SECOND REQUEST) > 15 Defendants. [16] $ & 17 Plaintiff Pricestack Inc. dba Preflect (“Preflect”) and Defendants Heart of Sun, LLC, Sophia Lima, and Nicholas Rus hereby stipulate as follows. (| 19 1. The parties stipulate to extend the time for Defendants to file an opposition 20 || to Plaintiff's Motion for Preliminary Injunction from September 27, 2022, to October 11, 21 || 2022, and for Plaintiff to file a reply from October 3, 2022 to October 17, 2022. 22 2. The parties stipulate to continue the hearing on Plaintiffs Motion for 23 || Preliminary Injunction to a date convenient for the Court on or after October 19, 2022. 24 3. Pursuant to Rule 65(b)(2), the parties stipulate to extend the duration of 25 || the temporary restraining order entered by the Court on September 9, 2022, (ECF No. 26 || 15) until the Court rules on Plaintiff's Motion for Preliminary Injunction. 27 4. The parties consent to this extension because they have reached a 28 || settlement in principle and require additional time to finalize the agreement. The parties 1 || anticipate submitting a stipulation to resolve this matter in the near future. 2 || DATED this 26th day of September, 2022. 3] LEWIS ROCA SANCHELIMA & ASSOCIATES, P.A. 4 ROTHGERBER CHRISTIE LLP 5 By: /s/ Michael J. McCue By: /s/ Chris Sanchelima 6 Michael J. McCue (SBN: 6055) Chris Sanchelima 3993 Howard Hughes Parkway, #600 235 SW 42 Ave 7 Las Vegas, Nevada 89169 Miami, Florida 33134 Telephone: (702) 949-8200 Telephone: (305) 447-1617 8 E-mail: mmccue@LewisRoca.com Email: Chris@sanchelima.com 9 Attorneys for Plaintiff Attorneys for Defendants Pricestack, Inc. Heart Of Sun, LLC; Sophia Lima; and Nicholas Rus [11] 12 | IT IS ORDERED that the hearing on plaintiff's motion for preliminary injunction 13 currently scheduled for October 5, 2022, is vacated and continued to November 1, 14 2022, at 4:00 p.m. by videoconference. 2 15 [16] IT |S SO ORDERED: 2 17 Dated: September 27, 2022 - a ANDREW P. GORDON 20 UNITED STATES DISTRICT JUDGE 2 21 [28] 9.