WNDG, LLC v. Lantow, as Trustee of The Susan Lantow Living Trust Dated May 26, 2006

Nevada Bar No.: 1798 Johnathon Fayeghi, Esq.

Nevada Bar No.: 12736 SKLAR WILLIAMS PLLC South Rampart Boulevard, Suite 350 Las Vegas, NV 89145 Telephone: (702) 360-6000 Facsimile: (702) 360-0000 Email: [email protected] [email protected] Attorneys for Defendant UNITED STATES DISTRICT COURT DISTRICT OF NEVADA WNDG, LLC, an Arizona limited liability CASE NO.: 2:24-cv-00263-CDS-BNW company, 12 Plaintiff, STIPULATION AND ORDER TO EXTEND DEADLINE FOR DEFENDANT 13 vs. TO ANSWER OR RESPOND TO PLAINTIFF’S COMPLAINT Susan Lantow as Trustee of The Susan Lantow (FIRST REQUEST) Living Trust Dated May 26, 2006.

Defendant.

17 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff WNDG, LLC (“Plaintiff”), through its undersigned counsel of record and Defendant Susan Lantow as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 (“Defendant”), through her undersigned counsel of record, as follows: 21 1. On February 6, 2024, Plaintiff filed its Complaint alleging claims for relief for breach of contract and negligent misrepresentation against Defendant. ECF 1.

2. On or about March 17, 2024, Plaintiff allegedly served the Summons and Complaint on Defendant. ECF 10.

3. Defendant was unable to retain counsel to respond to the Complaint until April 2, 2024.

1 4. Accordingly, pursuant to LR IA 6-1(a), the Parties wish to extend the deadline for || Defendant to respond to the Complaint by approximately 4 days in order to allow Defendant’s || counsel to adequately investigate the facts and prepare a responsive pleading.

4 5. For these reasons, the Parties stipulate and agree that Defendant shall have up to || and including April 12, 2024, within which to file her response to Plaintiff’s Complaint.

6 6. No discovery deadlines or dates for trial have been set.

7 7. This is the Parties’ first request to extend Defendant’s response deadline.

8 8. This stipulation is brought in good faith by the Parties and not for purposes of delay.

IT IS SO STIPULATED.

1] DATED this 8th day of April, 2024. DATED this 8th day of April, HOLLEY DRIGGS 2024. SKLAR WILLIAMS PLLC /s/ Don C. Fletcher /s/ Johnathon Faveghi □□□ McKay Holley, Esq. Frederic I. Berkley, Esq.

15 Nevada Bar No. 15934 Nevada Bar No. 1798 South Fourth Street, Suite 1600 Johnathon Fayeghi, Esq.

16 || Las Vegas, NV 89101 Nevada Bar No. 12736 [email protected] 410 S. Rampart Blvd., Ste. 350 17 -and- Las Vegas, NV 89145 FLETCHER BARNES LAW, PLC [email protected] || Don C. Fletcher, Esq. [email protected] Arizona Bar No. 012140 Attorneys for Defendant | 10429 South 51% Street, Suite 225 Phoenix, Arizona 85044 Attorneys for Plaintiff IT IS SO ORDERED.

Ling olen nh boom 23 ITED STATES MAGISTRATE JUDGE || DATED: _ 4/9/2024 From: John Fayeghi Sent: Monday, April 8, 2024 2:38 PM To: Amanda Brandon Cc: Frederic Berkley From: Don Fletcher <[email protected]> Sent: Monday, April 8, 2024 2:04 PM To: John Fayeghi <[email protected]> Cc: McKay Holley <[email protected]> Subject: FW: WNDG, LLC v. Susan Lantow as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 (Case 2:24-cv- 00263) External Email John: Yes, you have our permission to sign and file with the Court.

Thank you.

Don C. Fletcher FLETCHER BARNES LAW PLC 10429 South 51st Street, Suite 225 Phoenix, AZ 85044 602-523-3007 (Office) 602-471-8185 (cell) [email protected] www.fletcherbarneslaw.com CONFIDENTIALITY NOTICE This electronic transmission and any attachments are the confidential property of the sender, and the materials are privileged communications intended solely for the receipt, use, benefit, and information of the intended recipient indicated above. If you are not the intended recipient, you are hereby notified that any review, disclosure, copying, distribution, or the taking of any other action in reliance on the contents of this electronic transmission is strictly prohibited, and may result in legal liability on your part. If you have received this transmission in error, please notify Fletcher Barnes Law PLC immediately by telephone at (602) 523-3007 or by email at [email protected] and destroy this electronic transmission.

From: John Fayeghi <[email protected]> Sent: Monday, April 8, 2024 9:52 AM To: Don Fletcher <[email protected]>; [email protected] Cc: Frederic Berkley <[email protected]>; Amanda Brandon <[email protected]>; Timothy Barnes <[email protected]> Subject: RE: WNDG, LLC v. Susan Lantow as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 (Case 2:24-cv- 00263)