1 Charles E. Gianelloni, Esq. Nevada Bar No. 12747 2 Christian P. Ogata, Esq. Nevada Bar No. 15612 3 SNELL & WILMER L.L.P. 1700 S. Pavilion Center Drive, Suite 700 4 Las Vegas, Nevada 89135 Telephone: (702) 784-5200 5 Facsimile: (702) 784-5252 Email: [email protected] 6 [email protected] 7 Attorneys for Defendant Maestro 8 I ntegrations, LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 AMERICAN FIRE WIRE, INC., a domestic corporation, Case No. 3:24-cv-00517-MMD-CSD 12 Plaintiff 13 v. Stipulation and Order Permitting 14 Limited Jurisdictional Discovery and MAESTRO INTEGRATIONS, LLC, a Setting Briefing Deadline 15 foreign corporation; and DOES 1 through 10, inclusive, 16 Defendants 17 18 Plaintiff American Fire Wire, Inc. and specially appearing defendant Maestro Integrations, 19 LLC, stipulate to allow the parties to conduct limited jurisdictional discovery within 60 days of the 20 signing of a limited discovery plan and to set a briefing deadline following the period of 21 jurisdictional discovery: 22 1. Specially appearing defendant Maestro filed its motion to dismiss for lack of 23 personal jurisdiction on January 6, 2025. American Fire Wire filed a timely Opposition on January 24 21, 2024. In its Opposition, American Fire Wire argues there is sufficient evidence to establish 25 personal jurisdiction over Maestro in this matter. However, out of an abundance of caution, 26 American Fire Wire requested, as alternative relief, limited jurisdictional discovery if the Court 27 deems additional evidence necessary to determine if personal jurisdiction exists. To streamline 28 1 briefing, Maestro offered and American Fire Wire has agreed to a limited set of written discovery 2 and one deposition per side. 3 2. Federal Rule of Civil Procedure 26(d)(1) permits parties to stipulate to conduct 4 discovery before conducting a conference required by Rule 26(f). Consistent with that rule, courts 5 may order limited jurisdictional discovery if “pertinent facts bearing on the question of jurisdiction 6 are controverted.”1 7 3. The parties have agreed to a limited set of jurisdictional discovery for a period of 60 8 days that includes: 9 a. Scope of discovery 10 The scope of discovery for this period shall be limited to the parties’ disputes related to 11 whether specific personal jurisdiction exists over Maestro. This includes the facts asserted in the 12 parties’ respective declarations submitted as part of the briefing on the motions. 13 b. Written discovery requests 14 i. Number of requests 15  15 interrogatories per side 16  15 requests for production of documents per side 17  5 requests for admission per side 18 ii. Additional requests 19 If either side believes additional written discovery requests are necessary, that party may, 20 after making a good faith effort to meet and confer under LR IA 1-3(f), seek additional discovery 21 requests upon a showing of good cause. 22 c. Depositions 23 i. Number of depositions 24 The parties agree to one deposition per side of the individual who signed the declaration 25 submitted in support of the opposing party’s brief. 26 27 28 1 Boschetto v. Hansing,

(9th Cir. 2008). 1 ii. Form of depositions 2 The parties agree to conduct the depositions remotely under Rule 30(b)(4). The depositions 3 are not to exceed two hours each. 4 4. Separately, the parties agree that supplemental briefing on the motion may be 5 necessary following the limited discovery period and thus have agreed to permit American Fire 6 Wire to file a supplement to its opposition within 14 days after the close of the discovery period 7 and for Maestro to file its reply in support of the motion within 14 days after American Fire Wire 8 files its supplement. 9 5. Thus, the parties respectfully request that this Court: (1) permit the parties to 10 conduct a 60-day limited jurisdictional discovery period, as outlined in this stipulation; (2) permit 11 American Fire Wire to file a supplemental brief in opposition to Maestro’s deadline within 14 days 12 after the close of the discovery period; and (3) extend Maestro’s deadline to file its reply in support 13 of its motion to 14 days after American Fire Wire files its supplemental brief. 14 IT IS SO STIPULATED. 15 DATED: February 11, 2025 DATED: February 11, 2025 16 SNELL & WILMER L.L.P. LAXALT LAW GROUP, LTD. 17 By: /s/ Christian Ogata By: /s/ Sean Lancaster 18 Charles E. Gianelloni (NV Bar No. Jason W. Peak (NV Bar No. 7131) 12747) Sean H. Lancaster (NV Bar No. 16420) 19 Christian P. Ogata (NV Bar No. 15612) 9790 Gateway Drive, Ste. 200 1700 S. Pavilion Center Drive, Suite 700 Reno, Nevada 89521 20 Las Vegas, Nevada 89135 Attorneys for Plaintiff American Fire Wire, 21 Attorneys for Defendant Maestro Inc. Integrations, LLC 22 23 24 25 26 27 28 1 ORDER 2 Good cause appearing, IT IS HEREBY ORDERED that the parties’ stipulation is 3 || GRANTED. The parties have 60 days to conduct limited jurisdictional discovery. Each side shall 4 || be allowed to propound 15 interrogatories, 15 requests for production, and 5 requests for admission, 5 || each. Should either party believe additional written discovery requests are necessary, the party may, 6 || following a good faith effort to meet and confer, seek additional requests from the court upon a 7 || showing of good cause. Each party may conduct one deposition of the individual who signed the 8 || declaration submitted in support of the opposing party’s brief, not to exceed two hours, and 9 || conducted remotely. 10 IT IS FURTHER ORDERED that following the discovery period, Plaintiff shall have 14 11 || days to file a supplement to its Opposition to Maestro’s motion. Maestro shall then have 14 days 8 12 to file its reply in support of its motion to dismiss. 13 IT IS SO ORDERED. S28 14 DATED: February 12, 2025.

16 UNITED STATES GISTRATE JUDGE = 17 18 19 20 21 22 23 24 25 26 27 28 -4-