1 BJaEmCesK AST. BReOckMst r&om B, EECsqK STROM, LLP 2 Nevada Bar No. 14032 400 South 4th Street, Suite 650 3 Las Vegas, Nevada 89101 Telephone: (725) 300-0599 4 [email protected]

5 MANINGO LAW Lance A. Maningo, Esq. 6 Nevada Bar No. 6405 7 400 South 4th Street, Suite 650 Las Vegas, Nevada 89101 8 Telephone: (702) 626-4646 [email protected] 9 Attorneys for Defendants 10

11 UNITED STATES DISTRICT COURT

12 DISTRICT OF NEVADA 13 EVELYN DOUGLAS, an individual; 14 Case No.: 2:23-cv-00425-APG-BNW Plaintiff, 15 vs. 16

TDS FINANCIAL, LLC, a foreign limited- 17 liability company; TYLER STONE, 18 individually;

19 Defendants.

20 STIPULATION AND ORDER TO EXTEND RESPONSIVE PLEADING DEADLINE

21 Plaintiff Evelyn Douglas (“Plaintiff” or “Douglas”), by and through her counsel of record, 22 Kevin L. Hernandez, Esq., of the Law Office of Kevin L. Hernandez; and Defendants TDS 23 Financial, LLC and Tyler Stone (collectively “Defendants”), by and through their counsel of 24 record, James A. Beckstrom, Esq., with the law firm of Beckstrom & Beckstrom, LLP and Lance 25 A. Maningo, Esq., with Maningo Law (collectively the “Parties”), hereby stipulate and agree as 26 follows: 27 1. Plaintiff filed this action on March 22, 2023, and Defendants’ responsive pleading 28 deadline was April 17, 2023. ] 2. Counsel for Defendants have been retained by Beckstrom & Beckstrom, LLP and 2 || Maningo Law regarding the above lawsuit to serve as local counsel. 3 3. Lead counsel for Defendants is licensed in California and will be submitting the 4 || necessary Pro Hac Vice application to this Court. 5 4. The delay in submitting this Stipulation to the Court was the result of lead counsel 6 || for Defendants being hospitalized, which resulted in a delay and need for additional time to 7 || meaningfully respond to the Complaint. 8 5. Based on lead counsel’s medical condition and upon stipulation of the Parties, 9 || Defendants are seeking a three-week extension to file a responsive pleading. 10 6. The Parties stipulate and agree that Defendants’ time to file a responsive pleading 11 || shall be extended until May 8, 2023. 12 || Dated this 19th day of April 2023. Dated this 19th day of April 2023. 13. | BECKSTROM & BECKSTROM, LLP LAW OFFICE OF KEVIN L. HERNANDEZ 14 By: (s/_ James A. Beckstrom By: /s/ Kevin L. Hernandez Id James A. Beckstrom, Esq. Kevin L. Hernandez, Esq. 16 Nevada Bar No. 14032 Nevada Bar No. 12594

Street, Suite 650 8920 W. Tropicana Avenue, Suite 101 17 Las Vegas, Nevada 89101 Las Vegas, Nevada 89147 [email protected] [email protected] 18 Attorneys for Plaintiff MANINGO LAW 19 Lance A. Maningo, Esq. Nevada Bar No. 6405 20 400 So. 4th Street, Suite 650 Las Vegas, Nevada 89101 21 [email protected] 22 Attorneys for Defendants 23 ORDER 24 IT IS HEREBY ORDERED. 25 Dated this 20th day of April 2023. 26 7 ywlawehtn UNITED STATES MAGISTRATE JUDGE 28 Page 2 of 2