1 F. Christopher Austin, Esq. Nevada Bar No. 6559 [email protected] WEIDE & MILLER, LTD. 3 10655 Park Run Drive, Suite 100 Las Vegas, NV 89144 4|| Tel: (702) 382-4804 Fax: (702) 382-4805 Attorneys for Defendants, Jay Morrison Academy, LLC 6 || And Morrison Holdings, LLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 WILL ROUNDTREE, an individual, Case No.: 2:22-CV-1196 -RFB-DJA Plaintiff, 2 STIPULATION AND ORDER TO Vv. EXTEND THE DEADLINE TO 13 RESPOND TO THE COMPLAINT JAY MORRISON ACADEMY, LLC and 14 MORRISON HOLDINGS, LLC (First Request) 15 Defendants. 16 Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Rule 1A 6-1, Plaintiff WILL 17 ROUNDTREE and Defendants JAY MORRISON ACADEMY LLC (“JMA”) and MORRISON 18 HOLDINGS LLC (“MH”), by and through their respective counsel of record, Tiffany Hill of TH 19 Legal Consulting, LLC and Eric S. Powers of Powers Law on behalf of Plaintiff, and F. 20 Christopher Austin of Weide & Miller, Ltd., appearing on behalf of Defendants, hereby agree and 21 stipulate for an extension of time for Defendants to file and serve their answers or other responses 22 to the Complaint from the current deadline of August 18, 2022, up to and including September 9, 23 2022. This is the first request by the parties for such an extension. 24 Federal Rules of Civil Procedure 6(b) provides in pertinent part that “[w]hen an act may 25 or must be done within a specified time, the court may, for good cause, extend the time: (A) ... if 26 request is made, before the time or its extension expires ....” Fed. R. Civ. P. 6(b). Indeed, “[u]nder 27 Federal Rule of Civil Procedure 6(b), the court may, for good cause, extend a deadline if a request 28 & LID, is made “before the original time or its extension expires .... The Ninth Circuit has equated good PARK RUN DR.,

1 || cause with the exercise of due diligence.” Maxson v. H&R Block, Inc., Case No.: 2:16-cv-00152- 2 || APG-CWH,

, at *2 (D. Nev. Mar. 21, 2017) (citations omitted). 3 This stipulation is made before the expiration of the “original time” and good cause exists for the stipulated extension to provide Defendants with an opportunity to consult 5 || with their recently retained undersigned Defense counsel in this matter. Mr. Austin will be 6 |} out of the country in connection with a previously planned visit to family from August 21, 7 || 2022, through September 2, 2022, and will not be available to consult with Defendants on this 8 || matter until his return to his office on September 5, 2022. 9 For the foregoing reasons, the parties hereby stipulate to extend the deadline for the 10 || Defendants to answer or otherwise respond to the Complaint to September 9, 2022. 11 DATED: August 15, 2022. 12 IT IS SO AGREED AND STIPULATED: 13 WEIDE & MILLER, LTD. 14 By: /s/ Eric S. Powers, By: /s/ F. Christopher Austin Eric S. Powers, Esq. (NVB 12850) F. Christopher Austin, Esq. (NVB 6559) 15 POWERS LAW 10655 Park Run Drive, Suite 100 2460 Professional Court, Suite 200 Las Vegas, NV 89144 16 Las Vegas, NV 89128 caustin @ weidemiller.com eric @ericpowerslaw.com 702-382-4804 17 702-868-8000 Attorneys for Defendants, Jay Morrison 18 Tiffany Hill, Esq. Academy, LLC and Morrison Holdings, LLC 1 Pro Hac Vice Pending 9 TH LEGAL CONSULTING, LLC 0 PO Box 5302 Edmond, OK 73083 1 thlegalconsulting @ gmail.com 22 Attorneys for Plaintiff Will Roundtree 23 24 IT ISSQ.ORDERED: 25 \) 3 26 AY □□ O UNITED STATES\MAGISTRATE JUDGE 27 DATED: | August 16, 2022 28 & MILLER, LTD. PARK RUN DR.,