Lucky Lake Farm & Water Limited Partnership et al v. Clark et al
Plaintiff: Lucky Lake Farm & Water Limited Partnership and Swift River Farms Ltd.
Defendant: Rodney Koch, Gordon Clark, Cindy Lou Ellen Koch, Krystal Lee Clark, Michael Rose, Michael Rose & Associates Strategic Consulting Inc., Jeff Houghton, TW International Investments Ltd., TW Advisors Ltd., TW Funds Inc., La Bella Vita Equestrians LLC, La Bella Vita International Equine Sales LLC, Liquid Luxury Group LLC and Blackstone Luxury Group LLC
Case Number: 2:2023cv01768
Filed: October 30, 2023
Court: US District Court for the District of Nevada
Presiding Judge: Cam Ferenbach
Referring Judge: Gloria M Navarro
Nature of Suit: Fraud
Cause of Action: 28 U.S.C. ยง 1332 Diversity-Fraud
Jury Demanded By: Both
Docket Report

This docket was last retrieved on March 12, 2024. A more recent docket listing may be available from PACER.

Date Filed Document Text
December 20, 2023 Opinion or Order Filing 35 ORDER Granting #34 Stipulation for Extension of Time to Respond to #30 Amended Complaint. Gordon Clark answer due 1/9/2024; Krystal Lee Clark answer due 1/9/2024; Cindy Lou Ellen Koch answer due 1/9/2024; Rodney Koch answer due 1/9/2024. Signed by Magistrate Judge Cam Ferenbach on 12/20/2023. (Copies have been distributed pursuant to the NEF - AMMi)
December 19, 2023 Filing 34 STIPULATION FOR EXTENSION OF TIME (First Request) re #30 Amended Complaint by Defendants Gordon Clark, Krystal Lee Clark, Cindy Lou Ellen Koch, Rodney Koch. (Aldrich, John) (extend) (answer)
December 7, 2023 Opinion or Order Filing 33 ORDER Granting #32 Stipulation Extending Temporary Restraining Order. Responses due by 1/23/2024. Replies due by 1/30/2024. Motion Hearing set for 2/1/2024 at 09:00 AM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 12/7/2023. (Copies have been distributed pursuant to the NEF - AMMi)
December 7, 2023 Filing 32 STIPULATION Stipulation and [Proposed] Order Extending Temporary Restraining Order re #9 Temporary Restraining Order,, Ex Parte, serve only one side/party, by Defendants Gordon Clark, Krystal Lee Clark, Cindy Lou Ellen Koch, Rodney Koch. (Aldrich, John) (other) (injunctive)
December 5, 2023 Filing 31 CERTIFICATE OF SERVICE for #30 Amended Complaint by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd... (Flynn, Shamus)
December 5, 2023 Filing 30 First AMENDED COMPLAINT with Jury Demand against All Defendants by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Adds new parties. (Flynn, Shamus)
November 29, 2023 Filing 29 MINUTES OF PROCEEDINGS - Motion Hearing held on 11/29/2023 before Judge Gloria M. Navarro. Crtrm Administrator: NEV; Pla Counsel: Shamus Flynn, Esq. and Adam Jaffe, Esq.; Def Counsel: John P. Aldrich, Esq. for Defendants Gordon Clark, Krystal Lee Clark, Rodney Koch, and Cindy Lou Ellen Koch; Electronic Court Recorder Operator: Araceli Bareng; Recording start and end times: 2:02 p.m. - 2:16 p.m.; Courtroom: 7D.The Court makes preliminary statements and hears representations of counsel. IT IS ORDERED that the #9 Temporary Restraining Order is unsealed. IT IS FURTHER ORDERED re: Plaintiffs' #6 Motion for Preliminary Injunction that Responses are due by 12/7/2023 by 5:00 PM. Replies due by 12/12/2023 by 12:00 PM. The Temporary Restraining Order shall be extended to 5:00 PM on 12/13/2023. Motion Hearing set for 12/13/2023 at 9:00 AM in LV Courtroom 7D before Judge Gloria M. Navarro. The Court adjourns. (no image attached) (Copies have been distributed pursuant to the NEF - NEV)
November 29, 2023 Filing 28 NOTICE of Appearance by attorney John P. Aldrich on behalf of Defendants Gordon Clark, Krystal Lee Clark, Cindy Lou Ellen Koch, Rodney Koch. (Aldrich, John)
November 27, 2023 Filing 27 SUMMONS Returned Executed by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Cindy Lou Ellen Koch served on 11/16/2023. (Flynn, Shamus)
November 27, 2023 Filing 26 SUMMONS Returned Executed by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Rodney Koch served on 11/16/2023. (Flynn, Shamus)
November 27, 2023 Filing 25 SUMMONS Returned Executed by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Gordon Clark served on 11/16/2023. (Flynn, Shamus)
November 27, 2023 Filing 24 SUMMONS Returned Executed by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Krystal Lee Clark served on 11/16/2023. (Flynn, Shamus)
November 17, 2023 Filing 23 NOTICE of Lis Pendens by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. . (Flynn, Shamus)
November 17, 2023 Filing 22 NOTICE of Lis Pendens by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. -. (Flynn, Shamus)
November 17, 2023 Filing 21 MINUTE ORDER IN CHAMBERS of the Honorable Judge Gloria M. Navarro on 11/17/2023. Pending before the Court is Plaintiffs' #17 Ex Parte Motion to Extend Expiration of the TRO and Corresponding Deadlines. The Court entered the #9 TRO on November 13, 2023, with instructions for Plaintiffs to serve the TRO, Complaint, and Motion for Preliminary Injunction within 72 hours. Plaintiffs promptly filed proposed summonses, but the summonses did not issue until November 16, 2023. The #9 TRO is set to expire on November 27, 2023, 14 days after the TRO was entered. TROs generally cannot exceed 14 days "unless before that time the court, for good cause, extends it for a like period or the adverse party consents to a longer extension." Fed. R. Civ. P. 65(b)(2). Here, good cause exists to extend the expiration of the TRO because, to no fault of their own, Plaintiffs were not able to timely serve Defendants. Thus, the Court GRANTS the Motion to Extend but declines to adopt Plaintiffs' proposed dates. IT IS HEREBY ORDERED that (1) Plaintiffs are granted an additional 72 hours to serve Defendants now that the Summonses have issued; (2) the TRO expiration date is extended from November 27, 2023, at 5:00 p.m. to November 29, 2023, at 5:00 p.m.; (3) Defendants shall have until November 27, 2023, to file a Response to the #6 Motion for Preliminary Injunction; (4) Plaintiffs may file a Reply by November 28, 2023; and (5) the hearing currently set for November 27, 2023, at 10:00 a.m. is CONTINUED to November 29, 2023, at 2:00 p.m. in LV Courtroom 7D before Judge Gloria M. Navarro. (Copies have been distributed pursuant to the NEF - CMD)
November 16, 2023 Opinion or Order Filing 20 ORDER Granting #14 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Adam M. Jaffe for Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd. and approving Designation of Local Counsel Shamus S. Flynn. Signed by Judge Gloria M. Navarro on 11/16/2023. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website #www.pacer.gov(Copies have been distributed pursuant to the NEF - AMMi)
November 16, 2023 Filing 19 SUMMONS ISSUED as to Gordon Clark, Krystal Lee Clark, Cindy Lou Ellen Koch, Rodney Koch re #1 Complaint. (AMMi)
November 16, 2023 Filing 18 NOTICE of Corrected Image/Document re #14 Motion for Permission to Practice Pro Hac Vice - Verified Petition, for attorney Adam M. Jaffe, by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Service of corrected image is attached.). (Flynn, Shamus)
November 16, 2023 Filing 17 MOTION to Extend Time (First Request) re #9 Temporary Restraining Order,, Ex Parte, serve only one side/party, by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Responses due by 11/30/2023. (Attachments: #1 Notice of Motion, #2 Proposed Order, #3 Declaration)(Flynn, Shamus) (service)
November 16, 2023 Filing 16 MINUTE ORDER IN CHAMBERS of the Honorable Judge Gloria M. Navarro on 11/16/2023. Pending before the Court is the #14 Petition to Practice Pro Hac Vice, filed by Petitioner Adam M. Jaffe ("Petitioner"). The #14 Petition states that Petitioner is an attorney at Flynn Guidici, a law firm in Las Vegas, NV. An attorney may submit a verified petition to practice pro hac vice only if the attorney is not a resident of the State of Nevada and is not regularly employed in the State of Nevada. D. Nev. LR IA 11-2. Accordingly, IT IS HEREBY ORDERED that Petitioner show cause explaining how he meets the requirements to practice pro hac vice under the Court's local rules. IT IS FURTHER ORDERED that the Court DEFERS ruling on the #14 Petition. Petitioner shall have until November 30, 2023, to file a brief, not to exceed ten pages, explaining why the Court should grant his Petition. If Petitioner mistakenly put the wrong address for his law firm, he may correct his Verified Petition using the "Notice of Corrected Image/Document" event by November 30, 2023. Failure to timely comply with this Order WILL result in the denial of the Verified Petition and Petitioner's requirement to repay the filing fee.(Copies have been distributed pursuant to the NEF - CMD)
November 15, 2023 Filing 15 SUPPLEMENT to #14 Motion for Permission to Practice Pro Hac Vice - Verified Petition, by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd. (Attachments: #1 Exhibit A)(Flynn, Shamus)
November 14, 2023 Filing 14 REFER to ECF No. #18 Notice of Corrected Image/Document - MOTION/VERIFIED PETITION for Permission to Practice Pro Hac Vice by Adam M. Jaffe and DESIGNATION of Local Counsel Shamus S. Flynn (Filing fee $ 250 receipt number ANVDC-7493485) by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Flynn, Shamus) Modified on 11/16/2023 (CJS).
November 13, 2023 Filing 13 PROPOSED SUMMONS to be issued to Krystal Clark by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Flynn, Shamus)
November 13, 2023 Filing 12 PROPOSED SUMMONS to be issued to Rodney Koch by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Flynn, Shamus)
November 13, 2023 Filing 11 PROPOSED SUMMONS to be issued to Cindy Koch by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Flynn, Shamus)
November 13, 2023 Filing 10 PROPOSED SUMMONS to be issued to Gordon Clark by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Flynn, Shamus)
November 13, 2023 Opinion or Order Filing 9 TEMPORARY RESTRAINING ORDER Re: #6 Motion for Preliminary Injunction. Responses due by 11/20/2023. Replies due by 11/22/2023. Motion Hearing set for 11/27/2023 at 10:00 AM in LV Courtroom 7D before Judge Gloria M. Navarro. Signed by Judge Gloria M. Navarro on 11/13/2023. (Copies have been distributed pursuant to the NEF - ABG)
November 13, 2023 Filing 8 MINUTES OF PROCEEDINGS - Motion Hearing held on 11/13/2023 before Judge Gloria M. Navarro. Crtrm Administrator: NEV; Electronic Court Recorder Operator: Araceli Bareng; Recording start and end times: 9:06 a.m. - 9:09 a.m.; Courtroom: 7D. Counsel nor parties are present. As stated on the record, it appears no one received an electronic copy of the 7 Order. The Court will reissue the Order for Plaintiff's #6 Temporary Restraining Order and reset the motion hearing. The Court adjourns. Motion Hearing reset for 11/27/2023 at 10:00 AM in LV Courtroom 7D before Judge Gloria M. Navarro. (no image attached) (Copies have been distributed pursuant to the NEF - NEV)
October 31, 2023 Filing 5 MINUTE ORDER IN CHAMBERS of the Honorable Judge Gloria M. Navarro on 10/31/2023. Pending before the Court is the #3 Ex Parte Motion for Temporary Restraining Order. The #3 Motion also serves as a Motion for Preliminary Injunction. The Court instructs the Clerk of Court to file the #3 Motion on the docket again as a separate Motion for Preliminary Injunction.(Copies have been distributed pursuant to the NEF - CMD)
October 31, 2023 Filing 4 NOTICE TO COUNSEL PURSUANT TO LOCAL RULE IA 11-2. Counsel Adam M. Jaffe to comply with completion and filing of the Verified Petition and Designation of Local Counsel. For your convenience, click on the following link to obtain the form from the Court's website - #www.nvd.uscourts.gov. Upon approval of the Verified Petition, counsel is required to register for the Court's Case Management and Electronic Case Filing (CM/ECF) system and the electronic service of documents. Please visit the PACER website www.pacer.gov to register Attorney. Verified Petition due by 11/14/2023. (no image attached) (AMMi)
October 30, 2023 Filing 6 MOTION for Preliminary Injunction by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd. Responses due by 11/13/2023. (AMMi - per ECF No. 5 Minute Order)
October 30, 2023 Case randomly assigned to Judge Gloria M. Navarro and Magistrate Judge Cam Ferenbach. (AMMi)
October 30, 2023 Filing 3 EX PARTE MOTION for Temporary Restraining Order and Motion for Preliminary Injunction by Plaintiffs Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. (Attachments: #1 Declaration of Shamus Flynn, #2 Declaration of Mark Langefeld, #3 Declaration of Travis Stel, #4 Notice of Application/Motion, #5 Proposed Order)(Flynn, Shamus) (injunctive)
October 30, 2023 Filing 2 CERTIFICATE of Interested Parties by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd. that identifies all parties that have an interest in the outcome of this case. Other Affiliate Mark Langefeld, Other Affiliate Travis Stel for Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd. added. (Flynn, Shamus)
October 30, 2023 Filing 1 COMPLAINT against Gordon Clark, Krystal Lee Clark, Jeff Houghton, Cindy Lou Ellen Koch, Rodney Koch, Michael Rose & Associates Strategic Consulting Inc., Michael Rose, TW Advisors Ltd., TW Funds Inc., TW International Investments Ltd. (Filing fee $402 receipt number ANVDC-7476898) by Lucky Lake Farm & Water Limited Partnership, Swift River Farms Ltd.. Certificate of Interested Parties due by 11/9/2023. Proof of service due by 1/28/2024. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet) (Flynn, Shamus) NOTICE of Certificate of Interested Parties requirement: Under Local Rule 7.1-1, a party must immediately file its disclosure statement with its first appearance, pleading, petition, motion, response, or other request addressed to the court.

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Search for this case: Lucky Lake Farm & Water Limited Partnership et al v. Clark et al
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Defendant: Rodney Koch
Represented By: John P. Aldrich
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Defendant: Gordon Clark
Represented By: John P. Aldrich
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Defendant: Cindy Lou Ellen Koch
Represented By: John P. Aldrich
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Defendant: Krystal Lee Clark
Represented By: John P. Aldrich
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Defendant: Michael Rose
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Defendant: Michael Rose & Associates Strategic Consulting Inc.
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Defendant: Jeff Houghton
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Defendant: TW International Investments Ltd.
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Defendant: TW Advisors Ltd.
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Defendant: TW Funds Inc.
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Defendant: La Bella Vita Equestrians LLC
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Defendant: La Bella Vita International Equine Sales LLC
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Defendant: Liquid Luxury Group LLC
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Defendant: Blackstone Luxury Group LLC
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Plaintiff: Lucky Lake Farm & Water Limited Partnership
Represented By: Daniel Giudici
Represented By: Shamus Flynn
Represented By: Adam M. Jaffe
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Plaintiff: Swift River Farms Ltd.
Represented By: Daniel Giudici
Represented By: Shamus Flynn
Represented By: Adam M. Jaffe
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