1 ROBERT S. LARSEN, ESQ. Nevada Bar No. 7785 2 GORDON REES SCULLY MANSUKHANI, LLP 300 South 4th Street, Suite 1550 3 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 4 Facsimile: (702) 255-2858 E-Mail: [email protected] 5 Attorneys for Sequium Asset Solutions, LLC 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8

9 DEBORAH FOWLER, an individual, Case No.: 2:19-CV-01979-APG-DJA 10 Plaintiff, 11 vs. STIPULATION AND ORDER TO 12 EXTEND TIME FOR SEQUIUM ASSET SEQUIUM ASSET SOLUTIONS, LLC, a SOLUTIONS, LLC TO RESPOND TO 13 foreign limited-liability company,, COMPLAINT [ECF No. 1]

14 Defendants. (Second Request)

15

16 Pursuant to Local Rules 6-1 and 7-1, Plaintiff Deborah Fowler (“Plaintiff”), and 17 Defendant Sequium Asset Solutions, LLC (“Sequium”), by and through their respective 18 attorneys of record, stipulate as follows: 19 STIPULATION 20 1. Plaintiff filed her Complaint on November 13, 2019 [ECF No. 1].

21 2. Sequium was served with the summons and complaint on December 17, 2019. 22 3. Sequium with consent of Plaintiff submitted a Stipulation and Order to Extend 23 Time to respond to the Complaint [First Request] on January 7, 2020 [ECF No. 7]. 24 4. The Court issued its Order extending Sequium’s time to answer to January 28, 25 2020 [ECF Doc. 8]. 26 5. An additional two week extension is necessary to allow Sequium’s counsel to 27 continue its investigation and communication with the party who placed Plaintiff’s account with 1 |} Sequium. 2 6. The representative of the party who placed Plaintiff's account with Sequium was 3 || unavailable due to a death in the family. 4 7. Allowing a further short extension will also allow the parties to continue early 5 || resolution discussions. 6 8. Plaintiff has no objection to the extension. 7 9. Therefore, the parties agree that Sequium’s response to the Complaint is now 8 || due on or before February 11, 2020. 10 || DATED: January 27, 2020. DATED: January 27, 2020

5 11 || GORDON REES SCULLY COGBURN LAW 2s MANSUKHANI, LLP 4 wi 12 /S/ Robert S. Larsen /S/ Erik W. Fox 13 |] Sas Robert S. Larsen, Esq. Erik W. Fox, Esq. 4 14 Nevada Bar No. 7785 Nevada Bar No. 8804 2 Wing Yan Wong, Esq. James S. Cogburn, Esq. @ 15 || Nevada Bar No. 13622 Nevada Bar No. 8409

" Street, Suite 1550 2580 St. Rose Parkway, Suite 330 go 16 Las Vegas, NV 89101 Henderson, Nevada 89074 = Attorneys for Defendant Attorneys for Plaintiff Deborah Fowler & 17 || Sequium Asset Solutions, LLC 18 19 ORDER 20 IT IS SO ORDERED Ong

74 UNITED STATES MAGISTRATE JUDGE DATED: 1/31/2020

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