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    Winchell v. Narconon: Def. Withdraw Motion To Dismiss

    Uploaded by

    Tony Ortega
    This document is a notice of withdrawal filed by the defendant Narconon Fresh Start doing business as Rainbow Canyon Retreat. It withdraws two previous motions filed by the defendant: a motion to dismiss the plaintiffs' complaint for failure to state a claim and a reply in support of that motion to dismiss. It notifies the court that the defendant is withdrawing both of those previous filings in this case regarding claims made by the plaintiffs Lori Winchell, Ryan Winchell, and Jilliene Winchell against the defendant.

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    Winchell v. Narconon: Def. Withdraw Motion To Dismiss

    Uploaded by

    Tony Ortega
    89 views3 pages
    This document is a notice of withdrawal filed by the defendant Narconon Fresh Start doing business as Rainbow Canyon Retreat. It withdraws two previous motions filed by the defendant: a motion to dismiss the plaintiffs' complaint for failure to state a claim and a reply in support of that motion to dismiss. It notifies the court that the defendant is withdrawing both of those previous filings in this case regarding claims made by the plaintiffs Lori Winchell, Ryan Winchell, and Jilliene Winchell against the defendant.

    Original Description:

    Attorneys for Narconon Fresh Start withdraw their motion to dismiss

    Original Title

    Winchell v. Narconon: Def. Withdraw Motion to Dismiss

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    © © All Rights Reserved

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    This document is a notice of withdrawal filed by the defendant Narconon Fresh Start doing business as Rainbow Canyon Retreat. It withdraws two previous motions filed by the defendant: a motion to dismiss the plaintiffs' complaint for failure to state a claim and a reply in support of that motion to dismiss. It notifies the court that the defendant is withdrawing both of those previous filings in this case regarding claims made by the plaintiffs Lori Winchell, Ryan Winchell, and Jilliene Winchell against the defendant.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    89 views3 pages

    Winchell v. Narconon: Def. Withdraw Motion To Dismiss

    Uploaded by

    Tony Ortega
    This document is a notice of withdrawal filed by the defendant Narconon Fresh Start doing business as Rainbow Canyon Retreat. It withdraws two previous motions filed by the defendant: a motion to dismiss the plaintiffs' complaint for failure to state a claim and a reply in support of that motion to dismiss. It notifies the court that the defendant is withdrawing both of those previous filings in this case regarding claims made by the plaintiffs Lori Winchell, Ryan Winchell, and Jilliene Winchell against the defendant.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
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    4815-3267-9453.1
    LEWIS
    BRISBOIS
    BISGAARD
    &SMITHLLP
    ATTORNEYS AT LAW
    JOSH COLE AICKLEN
    Nevada Bar No. 007254
    DAVID B. AVAKIAN
    Nevada Bar No. 009502
    LEWIS BRISBOIS BISGAARD & SMITH LLP
    6385 S. Rainbow Boulevard, Suite 600
    Las Vegas, Nevada 89118
    702.893.3383
    FAX: 702.893.3789
    Attorneys for Defendant NARCONON FRESH START
    D/B/A/ RAINBOW CANYON RETREAT
    UNITED STATES DISTRICT COURT
    FOR THE DISTRICT OF NEVADA
    LORI WINCHELL, A Nevada Citizen; RYAN
    WINCHELL, a Nevada Citizen; and JILLIENE
    WINCHELL, a Nevada Citizen,
    Plaintiffs,
    vs.
    NARCONON FRESH START d/b/a RAINBOW
    CANYON RETREAT, a California Corporation;
    ASSOCIATION FOR BETTER LIVING AND
    EDUCATION INTERNATIONAL; NARCONON
    INTERNATIONAL AND DOES 1-100, roe
    Corporations I-X, inclusive,
    Defendants.
    CASE NO. 2:14-cv-00851-MMD-CWH
    DEFENDANT NARCONON FRESH START
    D/B/A RAINBOWCANYON RETREATS
    NOTICE OF WITHDRAWAL OF ITS
    MOTION TO DISMISS PLAINITFFS
    COMPLAINT FOR FAILURE TO STATE A
    CLAIMUPON WHICH RELIEF MAY BE
    GRANTED AND FOR OTHER RELIEF AND
    REPLY IN SUPPORT OF ITS MOTION TO
    DISMISS
    COMES NOW, Defendant NARCONON FRESH START d/b/a RAINBOW CANYON
    RETREAT (hereinafter referred to as FRESH START), by and through its attorneys of record,
    Josh Cole Aicklen, Esq. and David B. Avakian, Esq. of LEWIS BRISBOIS BISGAARD &
    / / /
    / / /
    Case 2:14-cv-00851-RFB-CWH Document 18 Filed 08/22/14 Page 1 of 3
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    4829-6789-0458.1 2
    LEWIS
    BRISBOIS
    BISGAARD
    &SMITHLLP
    ATTORNEYS AT LAW
    SMITH LLP, and hereby files this Notice of Withdrawal of its Motion to Dismiss for Failure to
    State a Claim Upon Which Relief May be Granted and for Other Relief, Document Number 12,
    filed on July 9, 2014 and its Reply in Support of its Motion to Dismiss, Document Number 15,
    filed on August 7, 2014.
    DATED this 22
    nd
    day of August, 2014.
    Respectfully submitted,
    LEWIS BRISBOIS BISGAARD & SMITH, LLP
    By /s/ David B. Avakian
    JOSH COLE AICKLEN
    Nevada Bar No. 007254
    6385 S. Rainbow Boulevard, Suite 600
    Las Vegas, Nevada 89118
    702.893.3383
    FAX: 702.893.3789
    Attorneys for Defendant NARCONON FRESH START
    D/B/A/ RAINBOW CANYON RETREAT
    Case 2:14-cv-00851-RFB-CWH Document 18 Filed 08/22/14 Page 2 of 3
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    4829-6789-0458.1 3
    LEWIS
    BRISBOIS
    BISGAARD
    &SMITHLLP
    ATTORNEYS AT LAW
    CERTIFICATE OF SERVICE
    Pursuant to FRCP 5(b), I certify that I am an employee of LEWIS BRISBOIS BISGAARD &
    SMITH LLP and that on this 22
    nd
    day of August 2014, I did cause a true copy of the foregoing
    DEFENDANT NARCONON FRESH START D/B/A RAINBOW CANYON RETREATS NOTICE
    OF WITHDRAWAL OF ITS MOTION TO DISMISS PLAINITFFS COMPLAINT FOR
    FAILURE TO STATE A CLAIM UPON WHICH RELIEF MAY BE GRANTED AND FOR
    OTHER RELIEF AND REPLY IN SUPPORT OF ITS MOTION TO DISMISS to be served via the
    CM/ECF electronic system to all parties on the service list.
    By: /s/ Susan Kingsbury
    An Employee of LEWIS BRISBOIS
    BISGAARD & SMITH LLP
    Case 2:14-cv-00851-RFB-CWH Document 18 Filed 08/22/14 Page 3 of 3

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