1 LIPSON NEILSON P.C. JOSEPH P. GARIN, ESQ. 2 Nevada Bar No. 6653 JONATHAN K. WONG, ESQ. 3 Nevada Bar No. 13621 9900 Covington Cross Drive, Suite 120 4 Las Vegas, Nevada 89144 Telephone: (702) 382-1500 5 Facsimile: (702) 382-1512 [email protected] 6 [email protected] 7 Attorneys for Defendants, The Dean Legal Group Ltd. and 8 Southern Capital Finance Group, LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 AUNDREA MACKLIN and KYLE REED, on ) Case No.: 2:22-cv-01057-APG-EJY behalf of themselves and others similarly ) 13 situated, ) ) STIPULATION AND ORDER TO 14 Plaintiffs, ) STAY CASE ) 15 v. ) ) 16 SOUTHERN CAPITAL FINANCE GROUP, ) LLC, a foreign limited-liability company; THE ) 17 DEAN LEGAL GROUP LTD., a domestic ) corporation; ) 18 ) Defendants. 19 ____________________________________ 20 Plaintiffs Aundrea Macklin and Kyle Reed (“Plaintiffs”) and Defendants Southern 21 Capital Finance Group, LLC and The Dean Legal Group Ltd. (collectively with Plaintiffs, 22 the “Parties”), by and through their respective counsel, hereby agree and stipulate as 23 follows: 24 The Parties stipulate and agree that, pursuant to Colorado River Water 25 Conservation Dist. v. United States,

,

,

(1976), this case shall be stayed pending final resolution of the case Aundrea Macklin et 27 al. v. Southern Capital Finance Group, LLC, et al., Case No. A-22-855007-C, currently 28 1 pending before Department XXXI of the Eighth Judicial District Court, Clark County, 2 Nevada. 3 The Parties further stipulate and agree that, as a result of the stay, responses to 4 the written discovery Plaintiffs served on the Dean Legal Group LTD and Southern 5 Capital Finance Group LLC on November 3, 2022 in the current case, originally due 6 December 5, 2022, are hereby stayed. 7 The Parties further stipulate and agree that, as a result of the stay, the Rule 8 30(b)(6) depositions for Southern Capital Finance Group, LLC, and The Dean Legal 9 Group Ltd., currently noticed for December 13, 2022 and December 15, 2022 10 respectively, are vacated. 11 The Parties further stipulate and agree that, within seven (7) days of the entry of 12 an order of this Court lifting the stay, the parties shall confer and agree on new dates for 13 the aforementioned Rule 30(b)(6) depositions and responses to Plaintiffs’ written 14 discovery requests. 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 The Parties have entered into this agreement in good faith and not for the 2 || purposes of prejudice or delay. 3 4 5 DATED this 7" day of December, 2022. DATED this 7" day of December, 2022.

6 LAW OFFICE OF KEVIN L. LIPSON NEILSON P.C. HERNANDEZ /8/ Kevin L. Hernandez /8/ Jonathan K. Wong By: _—s.-— _ 8 KEVIN L. HERNANDEZ, ESQ. JOSEPH P. GARIN, ESQ. 9 Nevada Bar No. 12594 Nevada Bar No. 6653 8920 W. Tropicana Avenue, Suite 101 JONATHAN K. WONG, ESQ. 10 Las Vegas, Nevada 89147 Nevada Bar No. 13621 Telephone: (702) 563-4450 9900 Covington Cross Drive, Suite 120 4 Facsimile: (702) 552-0408 Las Vegas, Nevada 89144 Telephone: (702) 382-1500 42 and Facsimile: (702) 382-1512 4g MICHAEL KIND, ESQ. 233 Nevada Bar No. 13903 Attorneys for Defendants 44 8860 South Maryland Parkway, Suite The Dean Legal Group Ltd. and ea 8 102 Southern Capital Finance Group, LLC 85% 15 Las Vegas, Nevada 89123 Telephone: (702) 337-2322 5 8 16 Facsimile: (702) 329-5881 2S 3488 47 Attorneys for Plaintiffs

19 || This stipulation is approved and this case is stayed. The pending motions to dismiss (ECF No. 9) and to stay (ECF No. 23) are denied without prejudice. The parties will file 20 a status report by June 16, 2023, and every six months thereafter. 21 22 | IT |S SO ORDERED: 23 Dated: December 8, 2022 24 ( ZA 25 ANDREW P. GORDON UNITED STATES DISTRICT JUDGE 26 27 28