Federal Trade Commission v. Ivy Capital, Inc.

1 Reilly Dolan Acting General Counsel P.Connell McNulty (PA Bar No. 87966) Federal Trade Commission 600 Pennsylvania Avenue, NW, CC-8528 Washington, DC 20580 202-326-2061 202-326-3395 (Fax) [email protected] Attorneys for Plaintiff Federal Trade Commission 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA FEDERAL TRADE COMMISSION, Civil Action No. 2:11-cv-00283-JCM-GWF Plaintiff, STIPULATION FOR EXTENSION OF v. 13 TIME FOR FEDERAL TRADE IVY CAPITAL, INC., et al., COMMISSION TO RESPOND TO 14 MOTION FOR RELIEF UNDER FED. R. Defendants, and CIV.P. 60(b) (ECF 449) 15 (FIRST REQUEST) CHERRYTREE HOLDINGS, LLC, et al., Relief Defendants.

19 On May 25, 2021, defendants Benjamin Hoskins and Dream Financial and relief defendants Leanne Hoskins, Oxford Financial LLC, and Mowab, Inc. moved under Fed. R. Civ. 21 P. 60(b) for relief from the “equitable monetary relief portion of the Court’s Final Judgment and Order for Permanent Injunction and Monetary Relief.” See ECF No. 449. The Court issued that underlying judgment on July 5, 2013. See ECF 409. Under L.R. 7-2(b), the Federal Trade Commission’s response to the Rule 60(b) motion is due by June 8.

25 On June 2, counsel for the FTC requested an extension of one week, through June 15, for |the FTC to respond to the motion. FTC counsel was not part of the original trial team on this |case, and the extension request was made to allow for additional case file review. Counsel for | the moving parties consented to the FTC’s request. This is the first stipulation for an extension 4 time to respond to the Rule 60(b) motion.

5 WHEREFORE, the FTC and the moving parties stipulate that the FTC shall have until 6 15, 2021, to respond to the Rule 60(b) motion (ECF No. 449).

8 SO STIPULATED, June 4, 2021.

10) 4/P. Connell McNulty | P- Connell McNulty Attorney for Federal Trade Commission |S/Pavid R. Koch David R. Koch | Daniel G. Scow Attorneys for Defendants Benjamin Hoskins and Dream Financial 16 Relief Defendants Leanne Hoskins, Oxford Financial LLC, and Mowab, Inc. 8 IT IS SO ORDERED: * ©. Malla 21 The Hohorable James C. Mahan 59 United States District Court Judge DATED: June 4, 2021 1 Certificate of Service 2 I hereby certify that on June 4, 2021, I electronically filed the foregoing document with the Court using CM/ECF, which will send a notice of electronic filing to all counsel of record.

5 Date: June 4, 2021 /s/ P. Connell McNulty P.Connell McNulty