Levels Network, Inc. v. Frey

1 | Marquis Aurbach Coffing Brian R. Hardy, Esq.

2. || Nevada Bar No. 10068 10001 Park Run Drive |] Las Vegas, Nevada 89145 Telephone: (702) 382-0711 || Facsimile: (702) 382-5816 [email protected] 5]| Attorneys for Defendant Jonas Frey 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA || LEVELS NETWORK, INC., a Delaware Case Number: corporation; and AW BETEILIGUNGS 2:21-CV-01796-RFB-BNW | GMBH, a limited liability company organized under the laws of Germany, 10 STIPULATION AND ORDER TO Plaintiffs, EXTEND BRIEFING SCHEDULE FOR O 11 . PLAINTIFFS’ MOTION FOR 5 vs. , PRELIMINARY INJUNCTION [ECF NO. 8] 6 # __ | JONAS FREY, an individual, og g 13 (First Request) x is Pursuant to LR IA 6-1 and 6-2, Plaintiffs Levels Network, Inc. and AW Beteiligungs 3 GMBH (collectively “Plaintiffs”), by and through their counsel of record, Kevin Murphy, Esq.

§ 7 (phv) of Wuersch & Gering LLP, and Brian W. Boschee and James B. Boyle, of Holley Driggs ig and Defendant Jonas Frey, by and through his counsel of record, Brian R. Hardy, Esq., of = Marquis Aurbach Coffing, hereby stipulate and agree to extend the briefing schedule for Plaintiffs’ Motion for Preliminary Injunction [ECF No. 8], as set forth in the Court’s Minute Order dated October 20, 2021 [ECF No. 18]. This Stipulation is being entered in good faith and not for purposes ofdelay. This is the parties first request for an extension to the briefing schedule.

1. On September 29, 2021 Plaintiffs filed their Motion for Preliminary Injunction.

ECF No. 8.

2. On October 7, 2021 Defendant was served with the Complaint. , Page | of 4 ‘ MAC: 16738-001 4516389_2 10/21/2021 8:33 AM 1 i On October 20, 2021, the Court issued a minute order that ordered Defendant | to respond to the Motion for Preliminary Injunction on or before October 21, 2021 and || Plaintiffs’ to file their reply on or before October 28, 2021. ECF No. 18.

4 4, The parties agree to extend the briefing schedule set by the Court in order to || continue with good faith discussions to reach a resolution of the issues raised in the Motion || for Preliminary Injunction, and potentially in the case overall.

7 5. The parties further agree that, should the Motion for Preliminary Injunction not |] be resolved between the parties, the Defendant’s response brief will then be due on or before || October 28, 2021.

10 6. The parties further agree that, should the Motion for Preliminary Injunction not || be resolved between the parties, Plaintiffs’ reply will be due on or before November 4, 2021.

12 7. The parties further agree to submit a proposed joint protective order to the | Court on or before October 28, 2021. This will assist in at least the facilitation of a settlement : ; E 14] of the Motion for Preliminary Injunction. Upon submission to the Court, the parties will abide | by the terms of the agreed proposed joint protective order until otherwise ordered by the Court. <8 3 16 IT IS SO STIPULATED.

3, 17] fl /// : = ft /// Page 2 of ? MAC: 16738-00! 4516389_2 10/21/2021 8:33 AM Dated this 21st day of October, 2021 Dated this 21st day of October, 2021 2|| HOLLEY DRIGGS MARQUIS RBACH COFFING Pyoes ZL James D. Boyle, Esq. a aiaal Es ES 4], Brian W. Boschee, Esq.

Nevada Bar No. 10068 400 South 4" Street 3% Floor 10001 Park Run Drive 5{| Las Vegas, Nevada 89101 Las Vegas, Nevada 89145 6] WUERSCH & GERING LLP Attorneys for Defendant Jonas Frey 7 3 □ : By: Ke i Murphy. + Esp}. (phv) WUERSCH & GERING LLP 100 Wall St. LO" Floor New York/NY 10005, 0 11 {| Attorneys for Plaintiffs AW Beteiligungs & Levels Network, Inc. 2g 13 é ORDER 15 IT IS SO ORDERED this 2!8t day of __ October 2021, pe 4- a | wont ll United States District Court 20 .

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