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EXHIBIT 2005
`
`
`Order Staying Proceedings
`
`

`
`Case 2:14-cv-01254-JLL-JAD Document 15 Filed 06/11/14 Page 1 of 3 PageID: 110
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEW JERSEY
`
`TRISTAR PRODUCTS, INC.,
`a Pennsylvania corporation,
`
`Plaintiff
`
`V.
`
`CHOON’S DESIGN, INC.
`a Michigan corporation,
`
`Defendant.
`
`BAKOS & KRITZER
`Noam J. Kritzer
`Edward P. Bakos
`147 Columbia Turnpike
`Florham Park, NJ 07932
`(908) 273-0770
`
`CounselJr Plaintiff
`
`Case No.: 2:14-cv-01254-JLL-JAD
`
`JURY TRIAL DEMANDED
`
`FREEMANN LAW OFFICES
`A PROFESSIONAL CORPORATION
`Scott Bennett Freemann
`2401 Walnut Street, Suite 302
`Philadelphia, PA 19103
`(215) 564-7400
`
`CARLSON, GASKEY & OLDS, P.C.
`Theodore W. Olds, III
`John M. Siragusa
`Brian S. Tobin
`To seek pro hac vice admittance
`400 West Maple Road, Ste. 350
`Birmingham, MI 48009
`(248) 988-8360
`
`Counsel for Dçfendant
`
`STIPULATION FOR STAY OF FURTHER PROCEEDINGS
`
`Defendant, Choon’s Design Inc., by its attorneys, Freemann Law Offices A Professional
`
`Corporation and Carison, Gaskey & Olds, P.C., and Plaintiff, Tristar Products, Inc., by its
`
`attorneys, Bakos & Kritzer, hereby stipulate and agree that, subject to court approval, all further
`
`proceedings in this matter shall be stayed until further order of this Court, pending resolution of
`
`

`
`Case 2:14-cv-01254-JLL-JAD Document 15 Filed 06/11/14 Page 2 of 3 PageID: 111
`
`Tristar’ s motion to dismiss due to lack of subject matter jurisdiction that will be filed in the next
`
`week in Michigan.
`
`1. Choon s Design LLC filed a patent infringement suit against Defendant in the Eastern
`
`District of Michigan. [Case No.: 2:14-cv-10848-VAR-MAR, Dkt. No. 1].
`
`2. Tristar Products, Inc. filed this declaratory judgment action in New Jersey after
`
`Choon’s Design, LLC filed the patent infringement suit. [Dkt. No. 1].
`
`3. Tristar Products, Inc. filed a motion to transfer the Michigan suit to New Jersey. [Case
`
`No.: 2:14-cv-10848-VAR-DRG, Dkt. No. 12].
`
`4. On May 8, 2014, Honorable Victoria A. Roberts of the Eastern District of Michigan
`
`issued an order denying the motion to transfer. [Case No.: 2:14-cv-10848-VAR-DRG, Dkt. No.
`
`18].
`
`5. Tristar intends to file a motion to dismiss Plaintiff’s patent infringement case in the
`
`Eastern District of Michigan on or before June 16, 2014, alleging that the Michigan Court lacks
`
`subject matter because Choon’ s Design, Inc. was the owner of the patents-in-suit at the time the
`
`Complaint was filed by Choon’s Design, LLC.
`
`6. The parties have agreed to stay this lawsuit pending resolution of the motion to dismiss
`
`in Michigan. For these reasons, the parties jointly request that all further proceedings in this
`
`matter shall be stayed until further order of this Court, pending resolution of the motion to
`
`dismiss in Michigan.
`
`Dated: June 10, 2014
`
`FREEMANN LAW OFFICES
`A PROFESSIONAL CORPORATION
`
`Is! Scott Bennett Freemann
`Scott Bennett Freemann
`2401 Walnut Street, Suite 302
`
`2
`
`

`
`Case 2:14-cv-01254-JLL-JAD Document 15 Filed 06/11/14 Page 3 of 3 PageID: 112
`
`____
`
`Philadelphia, PA 19103
`(215) 564-7400
`
`CARLSON, GASKEY & OLDS, P.C.
`Theodore W. Olds, III
`John M. Siragusa
`Brian S. Tobin
`To seekpro hac vice admittance
`400 West Maple Road, Ste. 350
`Birmingham, MI 48009
`(248) 988-8360
`
`Counselfor Defendant Choon ‘s Design, Inc.
`
`BAKOS & KRITZER
`
`Is! Noam J. Kritzer
`Noam J. Kritzer
`Edward P. Bakos
`147 Columbia Turnpike
`Florham Park, NJ 07932
`(908) 273-0770
`
`C’ounselfor Plaintff Tristar Products, Inc.
`
`-— / -———— /
`V
`
`p 4TV t’
`
`3

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