1 MICHAEL C. HETEY, ESQ. Nevada Bar No. 5668 2 HAROLD J. ROSENTHAL, ESQ. Nevada Bar No. 10208 3 THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER 4 1100 East Bridger Avenue Las Vegas, NV 89101-5315 5 Mail To: P.O. Box 2070 6 Las Vegas, NV 89125-2070 Tel.: (702) 366-0622 7 Fax: (702) 366-0327 [email protected] 8 [email protected]

9 Attorneys for Defendant, AMERICAN PACIFIC CORPORATION 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 LE PETOMANE XXVII, INC., an Illinois 13 corporation, not individually, but solely in its Case No. 2:21-cv-01166-APG-NJK representative capacity as trustee of the Nevada 14 Environmental Response Trust, STIPULATION AND ORDER FOR 15 Plaintiff, EXTENSION OF TIME FOR DEFENDANT AMERICAN PACIFIC 16 vs. CORPORATION TO RESPOND TO PLAINTIFF’S COMPLAINT (FIRST 17 AMERICAN PACIFIC CORPORATION, a REQUEST) Nevada corporation, 18 Defendant. 19

20 STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT AMERICAN PACIFIC CORPORATION TO RESPOND TO PLAINTIFF’S 21 COMPLAINT (FIRST REQUEST) 22 23 This is the First Request to extend the time for Defendant to respond to Plaintiff’s 24 Complaint. Defendant, American Pacific Corporation (“Defendant”), by and through its counsel, 25 Thorndal Armstrong Delk Balkenbush & Eisinger, and Plaintiff, Le Petomane XXVII, Inc. solely 26 in its representative capacity as trustee of the Nevada Environmental Response Trust 27 (“Plaintiff”), by and through its counsel, Fennemore Craig, P.C. and Foley & Lardner LLP (Pro 28 Hac Vice), hereby stipulate to allow Defendant a two (2) week extension to respond to Plaintiff’s 1 Complaint. Plaintiff filed its Complaint on June 21, 2021 and served Defendant with its 2 Complaint on June 24, 2021 making the current due date July 15, 2021. Plaintiff and Defendant 3 submitted a stipulation to the Court on July 12, 2021, stipulating to a two (2) week extension of 4 time to file a responsive pleading extending the time to July 29, 2021, but the stipulation was 5 denied without prejudice by the Court on July 13, 2021, citing a request for additional 6 information and compliance with Local Rule IA 6-1(a). 7 Pursuant to Local Rule IA 6-1(a), the basis for this first request stipulation for an 8 additional two-week time period to prepare and file a responsive pleading to Plaintiff’s 9 Complaint, is that Defendant is engaging additional counsel who will be joining the defense. 10 The additional counsel require the additional requested two (2) week time period to July 29, 11 / / / 12 / / / 13 / / / 14 / / / 15 / / / 16 / / / 17 / / / 18 / / / 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 1 || 2021, to assist with preparation of responsive pleadings. Said counsel will be applying for Pro 2 || Hac status in the near future as well. 3 Based upon the foregoing, Plaintiff and Defendant herby stipulate that Defendant ma 4 || file and serve its responsive pleading on or before July 29, 2021. || Dated this 13th day of July 2021. Dated this 13th day of July 2021. FENNEMORE CRAIG, P.C. THORNDAL ARMSTRONG DELK 7 BALKENBUSH & EISINGER 8 Il /s/ Josh Reid /s/ Michael C. Hetey JOSH REID, ESQ. MICHAEL C. HETEY, ESQ. 10 |} Nevada Bar No. 7497 Nevada Bar No. 5668

" Street, Suite 1400 HARRY J. ROSENTHAL, ESQ. Las Vegas, Nevada 89101 Nevada bar No. 10208 42 1100 East Bridger Avenue (Pro Hac Vice) Las Vegas, Nevada 89101 13 || ERIC L. MAASSEN, ESQ. Attorneys for Defendant, 14 WILLIAM J. MCKENNA, ESQ. AMERICAN PACIFIC CORPORATION, a TANYA C. O’NEILL, ESQ. Nevada corporation 15 || FOLEY & LARDNER LLP 777 East Wisconsin Avenue 16 || Milwaukee, Wisconsin 53202 47 Attorneys for Plaintiff, LE PETOMANE XXVII, INC. solely in its 18 || representative capacity as trustee of the NEVADA ENVIRONMENTAL RESPONSE 19 || TRUST 20 ORDER 21 IT IS SO ORDERED. 22 Dated: July 14, 2021 23 LPS 24 UNITED STATES. ISTRATE JUDGE 25 26 27 28