Electronically Filed
`Mar 31 2025 05:08 PM
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`Docket 90210 Document 2025-14508
`
`IN THE SUPREME COURT OF THE STATE OF NEVADA
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`
`
`Docket No. 90210
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`INDICATE FULL CAPTION:
`PORTEX GROUP, LLC and SAMSON
`NAZARYAN, individually,
`
`Appellants,
`
`vs.
`
`DONALD ALUISI, individually and
`COPPERBROOK LAS VEGAS, LLC,
`
`Respondents
`
`
`
`DOCKETING STATEMENT CIVIL APPEALS
`
`GENERAL INFORMATION
`Appellants must complete this docketing statement in compliance with Nevada
`Rules of Appellate Procedure (NRAP) 14(a). The purpose of the docketing
`statement is to assist the Supreme Court in screening jurisdiction, identifying issues
`on appeal, assessing assignment to the Court of Appeals under NRAP 17,
`scheduling cases for oral argument and settlement conferences, classifying cases for
`expedited treatment, and compiling statistical information.
`
`WARNING
`
`This statement must be completed fully, accurately, and on time. NRAP 14(c). The
`Supreme Court may impose sanctions on counsel or the appellant if it appears that
`the information provided is incomplete or inaccurate. Id. Failure to fill out the
`statement completely or to file it in a timely manner constitutes grounds for the
`imposition of sanctions, including a fine and/or dismissal of the appeal. Id.
`
`A complete list of the documents that must be attached appears as Question 28 on
`this docketing statement. Failure to attach all required documents will result in the
`delay of your appeal and may result in the imposition of sanctions. Id.
`
`This court has noted that when obligations under NRAP 14 to complete the
`
`Last updated 08/2024
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`docketing statement properly and conscientiously are not taken seriously, valuable
`judicial resources of this court are wasted, making the imposition of sanctions
`appropriate. See KDI Sylvan Pools v. Workman, 107 Nev. 340, 344, 810 P.2d 1217,
`1220 (1991). Please use divider pages to separate any attached documents.
`
`1. Judicial District: 8 County: Clark
`Judge: Danielle Pieper District Ct. Case No.: A-17-758437-C
`
`Department: 7
`
` Bar #: 13004
`
`
`2. Person filing this docketing statement:
`
` Name: Bryan Naddafi, Esq.
`
`
` Law Firm Name: Avalon Legal Group LLC
` Address: 6030 S. Rainbow Blvd, Suite D1, Las Vegas, NV 89118
` Telephone #: (702) 522-6450
` Email address: bryan@avalonlg.com
`Client name(s) (if represented by counsel): Protex Group LLC and
`Samson Nazaryan
`If this is a joint statement by multiple appellants, add the
`names and addresses of the other appellants and, if applicable,
`the names of their counsel and have them sign the certification
`below.
`
`
` Bar # (if applicable)
`
`
`
`
` Name
` Law Firm Name (if applicable)
` Address
` Telephone #
` Email address
`Client name(s) (if represented by counsel):
`
`Last updated 08/2024
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`2
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`I certify I concur in the filing of this statement.
`
` Signature of other appellant(s) or of counsel for other appellant Date
`
`
`
`3. Nature of disposition below (check all that apply):
` Judgment after bench trial
` Judgment after jury verdict
` Summary judgment
` Default judgment
` Grant/Denial of NRCP 60(b) relief
` Grant/Denial of injunction
` Dismissal:
` Lack of jurisdiction
` Failure to state a claim
` Failure to prosecute
` Other (specify):
` Divorce Decree:
` Original
` Modification
` Grant/Denial of declaratory relief
` Review of agency determination
` Other disposition (specify): _______________
`
`
`4. Does this appeal raise issues concerning any of the following?
`.Child Custody
`
` Venue
` Termination of parental rights
`
`
`5. Pending and prior proceedings in this court. List the case name and docket
`
`Last updated 08/2024
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`3
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`number of all appeals or original proceedings presently or previously pending
`before this court which are related to this appeal:
`Petition for Writ of Mandamus, 84423/84423-COA, denied on 11.23.2022.
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`
`
`
`
`
`
`6. Pending and prior proceedings in other courts. List the case name, number
`and court of all pending and prior proceedings in other courts which are related
`to this appeal (e.g., bankruptcy, consolidated or bifurcated proceedings) and
`their dates of disposition:
`N.A.
`
`7. Nature of the action. Briefly describe the nature of the action and the result
`below:
` This matter arises from claims by Plaintiffs/Respondents that
`Defendants/Appellants breached the grant of Reciprocal Easements and
`Declaration of Covenants for Rainbow-Mardon Commercial Centers (the
`"CCRs") and unlawfully interfered with their contractual relationships.
`Respondents alleged that Appellants falsely represented themselves as the
`successor Declaration of the Rainbow-Mardon Commercial Center
`Owners' Association ("Association") despite lacking the legal authority to
`do so. Respondents further alleged that acting under this false pretense,
`Appellants collected unauthorized assessments from Owner-Members,
`took control of Association affairs, and deprived Respondents of their
`rights under the CCRs, including the ability to vote for the Association's
`Board of Directors until January 2018. Respondents further contended
`that these actions disrupted contractual relationships with their tenants
`and resulted in financial harm.
` Respondents claim Appellants intentionally or negligently
`misrepresented their authority, creating an environment in which the
`Association could not properly function. Appellants allegedly failed to
`establish a Board of Directors in a timely manner and obstructed the
`Association's ability to levy lawful assessments. They further allegedly
`interfered with efforts to hire a new property management company,
`MDL Group, by refusing to pay their share of MDL Group's high fees
`and allegedly backing out of a written agreement made with MDL Group.
`This allegedly prevented MDL Group from assuming its responsibilities to
`the Association.
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`Last updated 08/2024
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` Appellants' actions allegedly extended beyond governance issues,
`directly impacting property value and financial stability within the
`commercial center. Respondents assert that Appellants prevented an
`attorney from incorporating the Association, forged Respondent Aluisi's
`signature, filed documents on behalf of the Association with the Nevada
`Secretary of State without Owner-Member approval, and disrupted
`contractual obligations.
` On February 20, 2024, the District Court filed an Amended Findings of
`Fact, Conclusion of Law, and Verdict. The court found in favor of
`Respondents on their negligence, breach of contract, breach of the implied
`covenant of good faith hand fair dealing, intentional interference with
`contractual relations, intentional misrepresentation (fraud), and negligent
`misrepresentation claims.
` The court found no evidence to support Respondents' claims for Unjust
`Enrichment or Libel/Defamation. The court also found no evidence to
`support Appellants' claims of Unjust Enrichment or Declaratory Relief.
` The court awarded Respondents general damages of $320,000,
`prejudgment interest to be computed from the date of the Answer
`through the date of the judgment, and attorneys' fees and costs of
`$587,552.77.
`
`8. Issues on appeal. State concisely the principal issue(s) in this appeal:
`1. Whether the District Court Judge erred in ruling that Appellant
`Nazaryan was the alter ego of Defendant Protex Group LLC.
`2. Whether the District Court Judge's award of $320,000 in general
`damages in favor of Respondents was an abuse of discretion.
`3. Whether the District Court Judge's award of $587,552.77 in attorneys'
`fees and costs against Appellants was an abuse of discretion.
`4. Whether the District Court Judge's denial of Appellants' Motion in
`Limine to Exclude/Strike Respondents' Expert, Keith Harper was an
`abuse of discretion.
`
`
`
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`
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`
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`9. Pending proceedings in this court raising the same or similar issues. If you
`are aware of any proceedings presently pending before this court which raises
`the same or similar issues raised in this appeal, list the case name and docket
`
`Last updated 08/2024
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`5
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`numbers and identify the same or similar issue raised:
`N.A
`
`10. Constitutional issues: Does this appeal challenge the constitutionality of a
`Nevada Statute or ordinance?
` No. Continue to #11.
` Yes:
`a. Identify the Nevada statute or ordinance being
`challenged:
`b. Is the State, any State agency, or a State officer or
`employee a party to this appeal in an official capacity?
`Yes
` No.
`
`
`
`
`
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`
`
`11. Other issues.
`a. Does this appeal involve any of the following issues?
` Reversal of well-settled Nevada precedent (identify the case(s))
` An issue arising under the United States and/or Nevada Constitutions
` A substantial issue of first impression
` An issue of public policy
` An issue where en banc consideration is necessary to maintain uniformity
`of this court's decisions
` A ballot question
`b. If so, explain:
`12. Assignment to the Court of Appeals or retention in the Supreme Court.
`Briefly set forth whether the matter is retained by the Supreme Court or
`presumptively assigned to the Court of Appeals under NRAP 17, and cite the
`subparagraph(s) of the Rule under which the matter falls.
`6
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`Last updated 08/2024
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`Due to the damages in this matter amounting to $320,000 which is in excess
`of $250,000 in tort case awards pursuant to NRAP 17(b)(5) and in excess of
`the $150,000 amount in controversy in a contract dispute pursuant to
`NRAP 17(b)(6), Appellants believe the instant matter is to be assigned to
`the Supreme Court.
`
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`13. Trial. If this action proceeded to trial, how many days did the trial last? 5
`days.
`Was it a:
`
`14. Judicial Disqualification. Do you intend to file a motion to disqualify or have
`a justice/judge recuse him/herself from participation in this appeal? See NRAP
`35. If so, which Justice/Judge? No.
`
` bench trial
`
` jury trial?
`
`
`15. Oral argument. Would you object to submission of this appeal for disposition
` Yes
`without oral argument?
` No
`
`TIMELINESS OF NOTICE OF APPEAL
`
`16. Date the written judgment(s) or order(s) appealed from was/were filed in the
`district court: 02/20/2025
`
`If no written judgment or order has been filed in the district court, explain
`the basis for seeking appellate review:
`
`
`
`
`17. Date written notice of entry of the judgment(s) or order(s) was/were served:
`02/20/2025____________
`Was service by:
` Electronic or personal delivery
` Mail
`
`
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`Last updated 08/2024
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`18. Were any motions seeking relief under NRCP 50(b), 52(b), 59, or 60 or seeking
`rehearing or reconsideration filed in the district court either before or after the
`notice of appeal was filed? (attach a copy of the motion)
` No, continue to # 19.
` Yes:
`a. Specify the type of motion and the date the motion was filed in the
`district court (check all that apply)
` NRCP 50(b)
`
`
`
`Date filed: _____________
` NRCP 52(b)
`
`
`Date filed: _____________
` NRCP 59
`
`
`
`Date filed: _____________
` NRCP 60
`
`
`
`Date filed: _____________
` Rehearing/Reconsideration
`Date filed: _____________
`b. Date the motion was served: _____________
`c. How was the motion served:
` Electronic or personal delivery
` Mail
`d. Date the written order resolving the motion was filed: _____________
`e. Date written notice of entry of the order resolving the motion was
`served: _____________
`f. Was service by:
` Electronic or personal delivery
` Mail
`19. Are there any motions other than those identified in #18 above still pending in
`the district court?
` Yes. Identify the motion and the date it was filed in the district court:
`Motion for Stay of Execution Pending Appeal - March 17, 2025.
` No.
`
`
`20. Date the notice of appeal was filed in the district court: 02/27/2025
`If more than one party has appealed from the judgment or order, list the date
`each notice of appeal was filed and identify by name the party filing the
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`Last updated 08/2024
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`notice of appeal:
`
`
`21. Specify the statute or rule governing the time limit for filing the notice of
`appeal, e.g., NRAP 4(a) or other: NRAP 4(a)
`
`SUBSTANTIVE APPEALABILITY
`22. Specify the statute or other authority granting this court jurisdiction to
`review the judgment or order appealed from:
`a.
`
` NRAP 3A(b)(1)
` NRAP 3A(b)(3)
` NRAP 3A(b)(5)
` NRAP 3A(b)(7)
` NRAP 3A(b)(9)
` NRAP 3A(b)(11)
` NRS 38.205
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` NRS 703.376
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`
`
`
`
`
`
`
`
`
`
` NRAP 3A(b)(2)
` NRAP 3A(b)(4)
` NRAP 3A(b)(6)
` NRAP 3A(b)(8)
` NRAP 3A(b)(10)
` NRAP 3A(b)(12)
` NRS 233B.150
`Other (specify): _____________
`
`
`
`
`
`
`
`b. Explain how each authority provides a basis for appeal from the judgment
`or order:
`Appellants are appealing a final judgment entered by the district court
`judge which constitutes a final judgment entered in the action commenced
`in the court in which the judgment was rendered.
`
`23. List all parties involved in the action or consolidated actions in the district court:
`a. Parties:
`Donald Aluisi
`Copperbrook Las Vegas LLC
`Portex Group, LLC
`Samson Nazaryan
`Marla Sobel a/k/a Marla Tobey
`Andrew Sobel
`Paul Slye
`Mass Equities, LLC
`
`Last updated 08/2024
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`Mass Equities, Inc.
`Triumph Property Management Corporation
`BCP-Rainbow Mardon LP
`BCP-R&M PAD C, LLC
`Rainbow Mardon Commerical Centers Owners Association
`Brentwood Capital Partners
`
`b. If all parties in the district court are not parties to this appeal, explain in
`detail why those parties are not involved in this appeal, e.g., formally
`dismissed, not served, or other:
`Marla Sobel a/k/a Marla Tobey - formally dismissed
`Andrew Sorbel - formally dismissed
`Paul Syle - formally dismissed
`Mass Equities LLC - formally dismissed
`Mas Equities, Inc. - formally dismissed
`BCP-Rainbow Mardon, LP - formally dismissed
`BCP-R&M PAD C, LLC - formally dismissed
`Rainbow-Mardon Commerical Center Owners' Assocaiation - formally
`dismissed
`Brentwood Capital Partners - formally dismissed
`Triumph Property Management Corp - formally dismissed
`
`24. Give a brief description (3 to 5 words) of each party's separate claims,
`counterclaims, cross-claims, or third-party claims and the date of formal
`disposition of each claim.
`Defendants/Appellants Counter-Claims and Third-Party Claims:
`1. Breach of Contract - 10/21/2019
`2. Breach of the Covenant of Good Faith and Fair Dealing - 10/21/2019
`3. Negligence - 10/21/2019
`4. Unjust Enrichment - 2/20/2025
`5.Accounting - 10/21/2019
`6. Declaratory Relief - 2/20/2025
`Plaintiffs/Respondents' Claims:
`1. Breach of Contract - 2/20/2025
`2. Breach of Covenant of Good Faith and Fair Dealing - 2/20/2025
`3. Intentional Intereference with Contractual Relations - 2/20/2025
`4. Intentional Misrepresentation (Fraud) - 2/20/2025
`5. Negligent Misrepresentation - 2/20/2025
`
`Last updated 08/2024
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`6. Unjust Enrichment - 2/20/2025
`7. Alter Ego - 2/20/2025
`8. Negligence - 2/20/2025
`9. Libel/Defamation - 2/20/2025
`
`
`
`25. Did the judgment or order appealed from adjudicate ALL of the claims alleged
`below and the rights and liabilities of ALL of the parties to the action or
` Yes
` No
`consolidated actions below?
`
`
`26. If you answered "No" to question 25, complete the following:
`a. Specify the claims remaining pending below:
`
`
`b. Specify the parties remaining below:
`
`
`c. Did the district court certify the judgment or order appealed from as a
`final judgment pursuant to NRCP 54(b)?
` Yes
` No
`
`d. Did the district court make an express determination, pursuant to NRCP
`54(b), that there is no just reason for delay and an express direction for
`the entry of judgment?
` Yes
` No
`
`
`27. If you answered "No" to any part of question 26, explain the basis for seeking
`appellate review (e.g., order is independently appealable under NRAP 3A(b)):
`
`
`28. Attach file-stamped copies of the following documents:
`• The latest-filed complaint, counterclaims, cross-claims, and third-party claims
`• Any motion(s) identified in questions 18 and the order(s) resolving the
`motion(s)
`• Any motions identified in question 19
`• Orders or NRCP 41(a)(1) dismissals that formally resolve each claim,
`counterclaim, cross- claim and/or third-party claim asserted in the action or
`consolidated action below, even if not at issue on appeal
`
`Last updated 08/2024
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`• All orders that finally disposes of any parties in the action below, even if not
`at issue on appeal
`• Any other order challenged on appeal
`• Notices of entry for each attached order
`
`VERIFICATION
`
`I declare under penalty of perjury that I have read this docketing statement,
`that the information provided in this docketing statement is true and
`complete to the best of my knowledge, information, and belief, and that I have
`attached all required documents to this docketing statement.
`
`___________________
`Bryan Naddafi, Esq.
`
` 3/31/2025
`Date
`
`State and county where signed
`State of Nevada, County of Clark
`
`CERTIFICATE OF SERVICE
`
`I certify that on the 31st day of March , 2025, I served a copy of this completed
`docketing statement upon all parties to this appeal:
` by electronic means to registered users of the court’s electronic
`filing system
`If served other than through the court's electronic filing system,
`enter the names and email address of the parties served by this
`means and attach a copy of each party’s written consent
`authorizing service by this means. See NRAP 25(c)(2)
`
`Last updated 08/2024
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` by personally serving it upon him/her;
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` by mailing it by first class mail with sufficient postage prepaid to the
`following address(es):
`
`__________________________
`Bryan Naddafi, Esq.
`
`3/31/2025
`Date
`
`Last updated 08/2024
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`Electronically Filed
`7/25/2018 11:35 AM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Case Number: A-17-758437-C
`
`

`

`—
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`Trial in this matter has not been set and no Scheduling Order has been entered. Each side is to
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`2||bear their own fees and costs.
`3
`DATEDthis AQdayofJuly, 2018
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`McCORMICK, BARSTOW, SHEPPARD,
`WAYTE & CARRUTH LLP
`
`By
`
`LOE.
`
`Philip A. John
`Nevada Bar No. 10627
`8337 West Sunset Road, Suite 350
`Las Vegas, Nevada 89113
`Tel. (702) 949-1100
`
`Attorneys forPlaintiff
`
`L
`DATEDthis 20dayofJuly, 2018
`MADDOX, ISAACSON&sea LLP
`LEFT ——>-
`
`By
`
`c= ae
`Troy L. Isaacson
`Nevada Bar No. 6690
`11920 Southern Highlands Parkway,#100
`Las Vegas, Nevada 89141
`
`Attorneys for Defendant, TRIUMPH PROPERTY
`MANAGEMENT CORPORATION
`
`ORDER
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`IT IS HEREBY ORDERED, ADJUDGED AND DECREEDthatthe above-
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`
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`23||entitled action be dismissed without prejudi
`24
`Dated thie day ofJuly, 201§
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`37||03577-00000 5227085.1
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`28
`McCormick, BARSTOW,
`SHEPPARD, WAYTE &
`CARRUTH LLP
`14S VEGAS NV AQIIT
`6397 W, SUNSETRO, SUITE 350
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`2
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`Electronically Filed
`7/27/2018 3:43 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Case Number: A-17-758437-C
`
`

`

`1
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`PLEASE TAKE NOTICE that the NOTICE OF ENTRY OF STIPULATION AND
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`2|}ORDER FOR DISMISSAL WITHOUT PREJUDICE AS TO TRIUMPH PROPERTY
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`3|}MANAGEMENT CORPORATION ONLYinthe above-captioned matter was entered on the 25"
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`4||day of July, 2018. A copy ofsaid Orderis attached hereto.
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`DATEDthis0|day ofJuly, 2018
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`McCORMICK, BARSTOW, SHEPPARD,
`WAYTE & CARRUTH LLP
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`By
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`y
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`- 4 J, ;
`ff A
`
`Philip A. John
`Nevada Bar No. 10627
`8337 West Sunset Road, Suite 350
`Las Vegas, Nevada 89113
`Tel. (702) 949-1100
`
`Attomey for Plaintiff
`
`CERTIFICATE OF SERVICE
`
`I herebycertify that on this.7 day ofJuly, 2018, a true and correct copy of NOTICE
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`16||OF ENTRY OF STIPULATION AND ORDERFORDISMISSAL WITHOUT PREJUDICE AS
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`17||TO TRIUMPH PROPERTY MANAGEMENT CORPORATION ONLYwasserved by
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`18||electronically filing with the Clerk ofthe Court using the Odyssey File & Serve system andservingall
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`19||parties with an email-address on record, who have agreedfo receiv Fectronic Servicein this action.
`20
`;
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`CH=
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`yee of
`“homas, an FE
`MCCORMICK,
`BARSTOW,
`WAYTE & CARRUTH LLP
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`SHEPPARD,
`
`By
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`oy)
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`McCormick, BARSTOW,
`SHEPPARD, WAYTE &
`CARRUTH LLP
`
`LAS VEGAS, NV 89113
`8337 W. SUNSETRO,SUITE 350
`
`D
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`Electronically Filed
`7/25/2018 11:35 AM
`Steven D. Grierson
`
`eeOFTHEae
`
`
`
`Philip A. John, Esq.
`Nevada Bar No. 10627
`McCORMICK, BARSTOW, SHEPPARD,
`WAYTE & CARRUTH LLP
`8337 West Sunset Road, Suite 350
`Las Vegas, Nevada 891 13
`Telephone:
`(702) 949-1100
`Facsimile:
`(702) 949-J101
`
`Attorneys for Plaintiff
`
`DISTRICT COURT
`
`CLARK COUNTY, NEVADA
`ktkk
`
`DONALD ALUISI, individually,
`
`Plaintiff,
`
`v,
`
`Case No. A-1 7-758437-C
`Dept. No.: 30
`
`STIPULATION AND ORDER FOR
`DISMISSAL WITHOUT PREJUDICE AS
`TO TRIUMPH PROPERTY
`MANAGEMENT CORPORATION ONLY
`
`PORTEX GROUP, LLC; SAMSON
`NAZARYAN, individually; MASS
`EQUITIES, LLC; ANDREW SOBEL,
`individually, BRENTWOOD CAPITAL
`PARTNERS; BCP-RAINBOW MARDON,
`LLC; MARLA SOBEL,individually; PAUL
`SLYE,individually, RAINBOW-MARDON
`COMMERCIAL CENTER OWNERS’
`ASSOCIATION; TRJUMPH PROPERTY
`MANAGEMENT CORPORATION;DOESI
`through X, inclusive; and ROE
`CORPORATIONSI through X,inclusive,
`
`Defendants.
`
`IT IS HEREBY STIPULATEDbythe parties above named, by and throughtheir respective
`
`counsel of record, that the above-entitled matter be dismissed without prejudice as to TRIUMPH
`
`PROPERTY MANAGEMENT CORPORATIONonly.
`
`{tl
`
`/f]
`
`fil
`
`‘il
`
`28
`McCoRMICK, BARSTOW,
`SHEPPARD, WAYTE &
`CARRUTH LLP
`8137 W, SUNSET RD, SUTE 740
`(AS UTTERGE
`
`Case Number: A-17-758437-C
`
`fs
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`eoNO
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`McCoanick, BARSTOW,
`SHEMPANG, WATTE &
`CARRUTH LLP
`8337 W., SUNSET RO, SUITE 350
`PAC EAN wy RUINS
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`Trial in this matter has not been set and no Scheduling Orderhas been entered. Eachsideis to
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`bear their own fees and costs.
`DATEDthis AQ)day of July, 2018
`
`McCORMICK, BARSTOW, SHEPPARD,
`
`WAYTE&I)LLPLLLPhilipA.we
`
`Nevada Bar No. 10627
`8337 West Sunset Road, Suite 350
`Las Vegas, Nevada 89113
`Tel. (702) 949-1100
`
`Attorneys for Plaintiff
`
`BP
`DATEDthis 20dayofJuly, 2018
`
`MADDOX, ISAACSON & CISNEROS,LLP
`
`
`
`Troy L. Isaacson
`Nevada BarNo. 6690
`11920 Southern Highlands Parkway, #100
`Las Vegas, Nevada 89141
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`Attorneys for Defendant, TRIUMPH PROPERTY
`MANAGEMENT CORPORATION
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`ORDER
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`IT IS HEREBY ORDERED, ADJUDGED AND DECREEDthatthe above-
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`entitled action be seyse without prejudice: “Eacl?s
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`ide ts to bear their own fees and costs.
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`Dated nis) dayofJuly, 2018
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`03577-00000 5227085 |
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`Electronically Filed
`12/10/2018 3:38 PM
`Steven D. Grierson
`CLERK OF THE COURT
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`Case Number: A-17-758437-C
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`14
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
`Corporations
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`COME NOW©Defendants/Counterclaimants/Thitd-Party Claimants,
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`11920SouthernHighlandsParkway,Suite100LasVegas,
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`Nevada89141
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`PORTEX GROUP,LLC; SAMSON
`NAZARYAN,individually,
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`Third-Party Plaintiffs,
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`MASS EQUITIES, LLC; MASS EQUITIES,
`INC.; ANDREW SOBEL,individually; BCP-
`RAINBOW MARDONLP; BCP-R&M PAD
`C, LLC; MARLA SOBEL a/k/a MARLA
`TOBEY,individually; DOESI through X,
`inclusive; and ROE CORPORATIONSI
`through X, inclusive,
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`Third-Party Defendants.
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`PORTEX GROUP, LLC and SAMSON NAZARYAN, by and through their
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`this Answer, Counter-Clatms, and Third-Party Claims as follows:
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`I
`PARTIES
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`1.
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`Answering Paragraph 1 of the Complaint, Answering Defendants admit
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`the allegations.
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`2.
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`Answeting Paragraph 2 of the Complaint, Answering Defendants admit
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`the allegations.
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`3.
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`Answering Paragraph 3 of the Complaint, Answering Defendants admit
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`the allegations.
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`4.
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`Answering Paragraph 4 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`counsel, the law firm of MADDOX|ISAACSON | CISNEROS LLP, and hereby submit
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
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`Corporations11920SouthernHighlandsParkway,Suite100LasVegas,
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`Nevada89141
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`5.
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`Answering Paragraph 5 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`i.
`JURISDICTION
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`6.
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`Answering Paragraph 6 of the Complaint, Answering Defendants admit
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`the allegations.
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`7.
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`Answeting Paragraph 7 of the Complaint, Answeting Defendants admit
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`the allegations.
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`8.
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`Answering Paragraph 8 of the Complaint, Answering Defendants admit
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`the allegations.
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`9.
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`Answering Paragraph 9 of the Complaint, Answering Defendants deny
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`the allegations.
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`10.
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`Answering Paragraph 10 of the Complaint, Defendant PORTEX
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`GROUP owns property within Commercial Center; Answering Defendants deny
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`they are “the current partial owner of the Commercial Center.”
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`11.
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`Answering Paragraph 11 of the Complaint, Answering Defendants deny
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`the allegations.
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`12.
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`Answering Paragraph 12 of the Complaint, Answering Defendants deny
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`the allegations.
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`13.
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`Answering Paragraph 13 of the Complaint, Answering Defendants
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`admit
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`that Defendant SAMSON NAZARYAN is
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`the director and officer of
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`Defendant PORTEX. Answering Defendants deny the remainderof the allegations.
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`14.
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`Answering Paragraph 14 of the Complaint, Answering Defendants
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`admit the allegations.
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`15.
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`Answering Paragraph 15 of the Complaint, Answering Defendants
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`admit that in or about January 2017, Defendant PORTEX purchased a portion of
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
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`Corporations11920SouthernHighlandsParkway,Suite100LasVegas,
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`Nevada89141
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`the Commercial Center. Answering Defendants deny the remainder of
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`the
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`allegations.
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`16.
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`Answering Paragraph 16 of the Complaint, Answering Defendants
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`denythe allegation.
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`17.
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`Answering Paragraph 17 of the Complaint, Answering Defendants
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`deny the allegation.
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`18.
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`Answering Paragraph 18 of the Complaint, Answering Defendants
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`admit the allegations.
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`19.
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`Answering Paragraph 19 of the Complaint, Answering Defendants
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`admit the allegations.
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`20,
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`Answering Paragraph 20 of the Complaint, Answering Defendants
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`admit the allegations.
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`Ill.
`GENERAL ALLEGATIONS
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`21.
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`Answering Paragraph 21 of the Complaint, Answering Defendants
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`repeat, re-allege, and incorporate by reference herein, their Answers set forth above,
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`as thoughfully set forth herein.
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`Answering Paragraph 22 of the Complaint, Answering Defendants lack
`22.
`knowledge or information sufficient to form a belief as to the truth ofthe allegations
`and therefore deny same.
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`23.
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`Answering Paragraph 23 of the Complaint, Answering Defendants lack
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`knowledge or informationsufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`24.
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`Answering Paragraph 24 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`25.
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`Answering Paragraph 25 of the Complaint, Answering Defendants
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`admit that the CC&Rs define the term “Owner” to include the record Ownerof fee
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`simple title to any lot or parcel within the Commercial Center. Answering
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`Defendants lack knowledge or information sufficient to form a belief as to the truth
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`of the remainder ofthe allegations and therefore deny same.
`26.
`Answering Paragraph 26 of the Complaint, Answering Defendants lack |
`knowledge or information sufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`27.
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`Answering Paragraph 27 of the Complaint, Answering Defendants
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`admit the allegations.
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`28.
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`Answering Paragraph 28 of the Complaint, Answering Defendants deny
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`the allegations.
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`29.
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`Answering Paragraph 29 of the Complaint, Answering Defendants deny
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`the allegations.
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`30.
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`Answering Paragraph 30 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the allegations
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`and therefore deny same.
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`31.
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`Answering Paragraph 31 of the Complaint,Answering Defendants lack
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`knowledge or informationsufficient to forma belief as to the truth of the allegations
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`and therefore deny same.
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`32.
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`Answering Paragraph 32 of the Complaint, Answering Defendants deny
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`the allegations.
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`33.
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`Answering Paragraph 33 of the Complaint, Answering Defendants deny
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`the allegations.
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`34.
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`Answering Paragraph 34 of the Complaint, Answering Defendants deny
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`the allegations.
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`35.
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`Answering Paragraph 35 of the Complaint, Answering Defendants deny
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`the allegations.
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`36.
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`Answering Paragraph 36 of the Complaint, Answering Defendants deny
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`the allegations.
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
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`Corporations11920SouthernHighlandsParkway,Suite100LasVegas,
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`Nevada89141
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`37.
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`Answering Paragraph 37 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth ofthe allegations
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`and therefore deny same.
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`38.
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`Answering Paragraph 38 of the Complaint,Answering Defendants deny
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`the allegations.
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`39.
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`Answering Paragraph 39 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to forma belief as to the truth ofthe allegations
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`and therefore deny same.
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`40.
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`Answering Paragraph 40 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth ofthe allegations
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`and therefore deny same.
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`41.
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`Answering Paragraph 41 of the Complaint, Answering Defendants deny
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`the allegations.
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`42.
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`Answering Paragraph 42 of the Complaint, Answering Defendants deny
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`the allegations.
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`43.
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`Answering Paragraph 43 of the Complaint, Answering Defendants deny
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`the allegations.
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`44.
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`Answering Paragraph 44 of the Complaint, Answering Defendants deny
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`the allegations.
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`45.
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`Answering Paragraph 45 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
`46.
`Answering Paragraph 46 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`47,
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`Answering Paragraph 47 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
`6
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
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`Corporations11920SouthernHighlandsParkway,Suite100LasVegas,
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`Nevada89141
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`48.
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`Answering Paragraph 48 of the Complaint, Answering Defendants deny
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`the allegations.
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`49.
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`Answering Paragraph 49 of the Complaint,Answering Defendants deny
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`the allegations.
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`50.
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`Answering Paragraph 50 of the Complaint, Answering Defendants
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`admit the allegations.
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`51.
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`Answering Paragraph 51 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`52.
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`Answering Paragraph 52 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`53.
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`Answering Paragraph 53 of the Complaint,Answering Defendants deny
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`the allegations.
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`54,
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`Answering Paragraph 54 of the Complaint, Answering Defendants deny
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`the allegations.
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`55.
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`Answering Paragraph 55 of the Complaint, Answering Defendants deny
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`the allegations.
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`56.
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`Answering Paragraph 56 of the Complaint, Answering Defendants lack
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`knowledge or informationsufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`57.
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`Answering Paragraph 57 of the Complaint, Answering Defendants lack
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`knowledge or information sufficient to form a belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`58.
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`Answering Paragraph 58 of the Complaint,Answering Defendants lack
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`knowledge or information sufficient to forma belief as to the truth of the remainder
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`of the allegations and therefore deny same.
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`///
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`LasVegas,Nevada89141
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`MADDOX|ISAACSON|CISNEROSLLPAnAssociationofProfessional
`Corporations
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`
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`11920SouthernHighlandsParkway,Suite100
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`Answering Paragraph 59 of the Complaint, Answering Defendants deny
`59.
`the allegations.
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`60.
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`Answering Paragraph 60 of the Complaint, Answering Defendants deny
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`the allegations.
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`61.
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`Answering Paragraph 61 of the Complaint, Answerin