Douglas Coder & Linda Coder Family LLLP v. RNO Exhibitions, LLC

1 || Janine C. Prupas, Bar No. 9156 Kiah D. Beverly-Graham, Bar No. 11916 || SNELL & WILMER Lv.

3 50 West Liberty Street, Suite 510 Reno, Nevada 89501 || Telephone: 775-785-5440 Facsimile: 775-785-5441 || Email: [email protected] 6 kbeverly @ swlaw.com Stephen J. Joncus, Admitted Pro Hac Vice JONCUS LAW P.c.

8 || 13203 SE 172™ Ave. Ste 166 #344 Happy Valley, Oregon 97086 || Telephone: 971-236-1200 10 Facsimile: 971-244-7997 Email: steve @joncus.net Attorneys for Defendants || RNO Exhibitions LLC and Vincent Webb = 13 UNITED STATES DISTRICT COURT | DISTRICT OF NEVADA Bare 15 DOUGLAS CODER & LINDA CODER 3° 16 || FAMILY LLLP, Case No. 3:19-cv-00520-MMD-CLB 17 Plaintiffs, STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND || Vv: TO COMPLAINT TO OCTOBER 390, 2020 |} RNO EXHIBITIONS, LLC, a Nevada limited liability company; and VINCENT WEBB, an (FIRST REQUEST) || individual, 2] Defendants.

23 Pursuant to Local Rule 7-1, Plaintiffs Douglas Coder & Linda Coder Family LLLP || (“Plaintiffs”) and Defendants RNO Exhibitions, LLC and Vincent Webb (“Defendants”, and || together with Plaintiffs, the “Parties”), by and through their respective undersigned counsel of || record, submit this Stipulation and Proposed Order.

27 Plaintiff filed and served an Amended Complaint on April 20, 2020 (ECF No. 37) (the || “FAC’); 1 Defendants timely filed Motions to Dismiss the FAC on May 20, 2020 (ECF Nos. 42 and || 43); 3 On October 9, 2020, the Court entered an Order granting in part and denying in part the || Motions to Dismiss (ECF No. 56); 5 Defendants’ deadline to respond to the FAC’s surviving allegations is October 23, 2020; || and 7 This is the Parties’ first request for an extension of time to respond to the FAC and is not || intended to cause any delay or prejudice to any party. The reason for the extension is to give || Defendants time to evaluate and respond to the allegations set forth in the FAC.

10 IT IS HEREBY STIPULATED AND AGREED by and between the Parties that the time || for Defendants to respond to the FAC in this action is extended to and through October 30, 2020.

12 Dated: October 21, 2020 Dated: October 21, 2020 | 13 KAEMPFER CROWELL SNELL & WILMER L.L.P. By: /s/Alex J. Flangas (with permission) 1S Alex J. Flangas, Esq. NV Bar 664 By: Kiah D. Beverly-Graham 6 50 W Liberty St., Suite 700 Janine C. Prupas, No. 9156 2 Reno, NV 89501 Kiah D. Beverly-Graham, No. 11916 17 50 West Liberty Street, Suite 510 Attorneys for Plaintiffs Douglas Coder & Reno, Nevada 89501 || Linda Coder Family LLLP Stephen J. Joncus 19 Admitted Pro Hac Vice JONCUS LAW P.C. 13203 SE 172"! Ave Ste 166 #344 21 Happy Valley, Oregon 97086 Attorneys for Defendants 22 RNO Exhibitions LLC and Vincent Webb ORDER 25 IT IS SO RED: 27 UNITED STAT AGISTRATE JUDGE || DATED: October 21, 2020 _2- 1 CERTIFICATE OF SERVICE 2 I hereby certify that on this date, I electronically filed the STIPULATION AND ORDER | TO EXTEND DEADLINE TO RESPOND TO COMPLAINT TO OCTOBER 30, 2020 || (FIRST REQUEST) with the Clerk of the Court for the U.S. District Court, District of Nevada || by using the Court’s CM/ECF system. Participants in the case who are registered CM/ECEF users || will be served by the CM/ECF system.

7 DATED: October 21, 2020 By /s/ Lara J. Taylor 9 An employee of Snell & Wilmer L.L.P. | 13 | 16 _3-