1 Analise N. M. Tilton Nevada Bar No. 13185 2 Nicholas F. Adams Nevada Bar No. 14813 3 WOOD, SMITH, HENNING & BERMAN LLP 2881 Business Park Court, Suite 200 4 Las Vegas, Nevada 89128-9020 Phone: 702 251 4100 ♦ Fax: 702 251 5405 5 [email protected] [email protected] 6 Attorneys for Defendant Cheap Tech Guys LLC 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 MICROSOFT CORPORATION, a Case No. 2:21-cv-00284-APG-VCF Washington Corporation, 12 STIPULATION AND ORDER TO Plaintiff, EXTEND TIME FOR DEFENDANT, 13 CHEAP TECH GUYS LLC TO RESPOND v. TO PLAINTIFF'S COMPLAINT 14 CHEAP TECH GUYS LLC, a Nevada (FIRST REQUEST) 15 Limited Liability Company, Trial Date: None Set 16 Defendant. 17 18 STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT, CHEAP TECH GUYS LLC TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST) 19 20 CHEAP TECH GUYS LLC (hereinafter "Defendant") and MICROSOFT CORPORATION 21 (hereinafter "Plaintiff") (collectively, "the Parties") by and through their respective counsel, hereby 22 stipulate and agree that Defendant, CHEAP TECH GUYS LLC shall have until April 15, 2021 to 23 respond to Plaintiff's Complaint filed on February 19, 2021. See ECF No. 1. This extension would 24 be the first extension of time granted for Plaintiff to respond to the Complaint. 25 I. Reasons For the Requested Extension 26 Plaintiff filed its Complaint on February 19, 2021. See ECF No. 1. Subsequently, Defendant 27 was served on March 8, 2021. See ECF No. 14. Thereby making the time to respond to the Complaint 1 to the Complaint had expired. 2 When the counsel was retained for Defendant, counsel reached out to Plaintiff's counsel for 3 an extension, which Plaintiff's counsel graciously granted. 4 Since Defendant's counsel was unable to prepare a response to Plaintiff's Complaint before 5 they were retained, excusable neglect exists. Clark v. Coast Hotels & Casinos, Inc.,

6 (2014) ("excusable neglect" applies to "instances where some external factor beyond a party's 7 control affects the party's ability to act or respond as otherwise required"). 8 Accordingly, the Parties stipulate and agree that Defendant, CHEAP TECH GUYS LLC 9 shall have until April 15, 2021 to respond to Plaintiff's Complaint filed on February 19, 2021. See 10 ECF No. 1. 11 DATED: April 13, 2021 WOOD, SMITH, HENNING & BERMAN LLP 12 13 By: /s/ Nicholas F. Adams 14 ANALISE N. M. TILTON Nevada Bar No. 13185 15 NICHOLAS F. ADAMS Nevada Bar No. 14813 16 2881 Business Park Court, Suite 200 Las Vegas, Nevada 89128-9020 17 Phone: 702 251 4100 18 Attorneys for Defendant, Cheap Tech Guys LLC 19 20 DATED: April 13, 2021 GREENBERG TRAURIG, LLP 21 22 23 By: /s/ Christopher R. Miltenberger CHRISTOPHER R. MILTENBERGER 24 Nevada Bar No. 10153 10845 Griffith Peak Drive, Suite 600 25 Las Vegas, Nevada 89135 Phone: 702 792 3773 26 27 Attorneys for Plaintiff, Microsoft Corporation 1 ORDER 2 The Court having reviewed the foregoing STIPULATION AND ORDER TO EXTEND 3 || TIME FOR DEFENDANT, CHEAP TECH GUYS LLC TO RESPOND TO PLAINTIFF'S 4 |} COMPLAINT (FIRST REQUEST) in the above-entitled matter and for good cause appearing 5 || therefor: 6 IT IS SO ORDERED that Defendant, CHEAP TECH GUYS LLC shall have until April 7 {| 15, 2021 to respond to Plaintiff's Complaint filed on February 19, 2021. See ECF No. 1. 4-13-2021 9 Dated: . . ce a at

M U.S. MAGISTRATE JUDGE (12 15 2 16 SF a7 18 19 20 21 22 23 24 25 26 27 28 20772549.1:10836-0086 -3- Case No. 2:21-cv-00284-APG-VCF

1 CERTIFICATE OF SERVICE 2 I hereby certify that on this 13th day of April, 2021, a true and correct copy 3 ofSTIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT, CHEAP TECH GUYS 4 LLC TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST) was served via the 5 United States District Court CM/ECF system on all parties or persons requiring notice. 6 7 8 9 By /s/ Johana Whitbeck Johana Whitbeck, an Employee of 10 WOOD, SMITH, HENNING & BERMANLLP 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27