Levels Network, Inc. v. Frey

1 Marquis Aurbach Coffing Brian R. Hardy, Esq.

2 Nevada Bar No. 10068 Susan E. Gillespie, Esq.

3 10001 Park Run Drive Las Vegas, Nevada 89145 Telephone: (702) 382-0711 Facsimile: (702) 382-5816 [email protected] [email protected] Attorneys for Defendant Jonas Frey 7 UNITED STATES DISTRICT COURT 8 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, 11 STIPULATION AND ORDER TO Plaintiffs, EXTEND BRIEFING SCHEDULE FOR 12 PLAINTIFFS’ MOTION FOR vs. PRELIMINARY INJUNCTION 13 [ECF NO. 8] JONAS FREY, an individual, 14 (Second Request) Defendant.

Pursuant to LR IA 6-1 and 6-2, Plaintiffs Levels Network, Inc. and AW Beteiligungs GMBH (collectively “Plaintiffs”), by and through their counsel of record, Kevin Murphy, Esq. (phv) of Wuersch & Gering LLP, and Brian W. Boschee and James D. Boyle, of Holley Driggs 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] and extended per the Stipulation and Order to Extend Briefing Schedule for Plaintiffs’ Motion for Preliminary Injunction dated October 21, 2021 [ECF No. 21]. This Stipulation is being entered in good faith and not for purposes of delay. This is the parties second request for an extension to the briefing schedule.

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

ECF No. 8.

Page 1 of 3 1 2. On October 7, 2021 Defendant was served with the Complaint.

2 3. 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.

5 4. On October 21, 2021, the parties stipulated to and the Court granted an extension to 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. ECF No. 21.

9 5. The parties agree to extend the briefing schedule a second time 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.

12 6. 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 November 2, 2021.

15 7. 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 9, 2021.

17 IT IS SO STIPULATED.

18 /// /// /// Page 2 of 3 Dated this 28th day of October, 2021 Dated this 28th day of October, 2021 || HOLLEY DRIGGS MARQUIS AURBACH COFFING By: __s/ James D. Boyle, Esq.___ By: _s/Brian R. Hardy, Esq.

James D. Boyle, Esq. . Brian R. Hardy, Esq.

5|| Brian W. Boschee, Esq. Nevada Bar No. 10068 th rd . 400 South 4" Street 3°° Floor .

Las V Nevada 89101 10001 Park Run Drive 6 as Megas, Nevada Las Vegas, Nevada 89145 WUERSCH & GERING LLP Attorneys for Defendant Jonas Frey By: s/ Kevin Murphy, Esq.

Kevin Murphy, Esq. (phv) 101 WUERSCH & GERING LLP | 100 Wall St. 10° Floor New York, NY 10005 || Attorneys for Plaintiffs AW Beteiligungs & Levels Network, Inc. se 3 16 IT IS SO ORDERED this 31st day of __ October , 2021.

“Se 9? want tS I 20 United States District Court Page 3 of 3 MAC:16738-001 4523371_1 10/28/2021 8:26 AM