1 | HONE LAW Jennifer W. Arledge, NV Bar No. 8729 2 ||\[email protected] Kelly B. Stout, NV Bar No. 12105 3 || [email protected] 701 N. Green Valley Parkway, Suite 200 4 || Henderson, NV 89074 Phone 702-608-3720 5||Fax 702-608-7814 6|DORSEY & WHITNEY LLP Daniel J. Brown, MN Bar No. 0298992 * 7 | Brown. [email protected] F. Matthew Ralph, MN Bar No. 0323202 * 8 | Ralph. [email protected] 50 South Sixth Street, Suite 1500 9 || Minneapolis, MN 55402 Phone 612-343-2183 10]Fax 612-340-2807 11 Admitted pro hac vice 12 || Attorneys for Defendant Deluxe Smail Business Sales, Inc. 13 14 UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA 16 ||INC AUTHORITY, LLC, a Nevada Company, | Case No. 2:24-cv-02394-APG-DJA 17 Plaintiff, 18 STIPULATION AND ORDER TO STAY DISCOVERY 19 | DELUXE SMALL BUSINESS SALES, INC., A Minnesota Corporation; HOSTOPIA., a (First Request) 20 || Canadian Corporation dba Deluxe and/or HOSTPAPA; DOES I through X and ROE 21 ||Corporations or Business Entities I through X, inclusive, 22 Defendants. 23 24 Defendant Deluxe Small Business Sales, Inc. (“Deluxe”), and Plaintiff Inc Authority, 25 ||LLC (“Plaintiff”), by and through undersigned counsel, and pursuant to Federal Rules of Civil 26 || Procedure 16 and 26, and Local Rule 16-1, hereby stipulate and agree as follows: /

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1 l. On November 8, 2024, Plaintiff Inc Authority, LLC filed its Complaint in the 2||Eighth Judicial District Court of the State of Nevada, Case No. A-24-905773-C (“State Court 3 | Action”). (ECF No. 1-1.) 4 2. On November 25, 2024, Deluxe was served with a copy of the Complaint and 3 Summons in the State Court Action. 6 3. On December 23, 2024, Deluxe appeared in the case by filing its Notice of 7|Removal in this Court (ECF No. 1) and its Notice of Removal of Action Pursuant to 28 U.S.C. 81/§§ 1332 in the State Court Action. 9 4, On January 2, 2025, Deluxe filed Defendant’s Rule 12(B)(3) Motion to Dismiss, 10 }/or in the Alternative, to Transfer to the District of Minnesota (“Motion to Dismiss or Transfer”) 11 || (ECF Nos. 6 & 7) which is pending before the Court. 12 5: The Motion to Dismiss or Transfer has been fully briefed as of January 21, 2025, 13 land is pending a decision. 14 6. Defendant Hostopia as referenced in the caption has not been served. 15 7. If granted, the Motion to Dismiss or Transfer would result in the transfer or 16 || dismissal of all claims asserted in the Complaint. 17 8. On or about February 10, 2025, counsel for Plaintiff and Deluxe conferred via 18 | email regarding whether and to what extent to engage in discovery, consistent with Rule 26(f). 19 Given the outstanding motion to dismiss or transfer, and the uncertainty created thereby, Plaintiff 20 |jand Deluxe agree and submit that good cause exists to postpone the Rule 26(f) conference, 21 || production of initial disclosures under Rule 26(a)(1)(C), and the entry of a scheduling order by 22 |\the court, until after the entry of an order on the Motion to Dismiss or Transfer. 23 |/// 24\1/// 25 1/// 26 \/// // //

1 9. If the Motion to Dismiss or Transfer is denied, then the parties shall conduct the 2 || Rule 26(f) conference within 14 days of entry of the order denying the motion and file the 3 || discovery plan within 14 days after the Rule 26(f) conference is held. 4 Dated this 18 th day of February 2025. 5 || HONE LAW Kurt K. Harris, Esq., P.C. 6 MIs ‘ [bbe PLR _ 7 | Jexmifer W/ Arledge, NV Bar (0/ 8729 Kurt V Bar No. 5354 “14 [email protected] kharris law.com 8 Kelly B. Stout, NV Bar No. 12105 7435 W. Azure Drive, Suite 110 [email protected] Las Vegas, Nevada 89130 9/701 N. Green Valley Parkway, Suite 200 Henderson, NV 89074 Attorneys for Plaintiff 10 Ine Authority LLC DORSEY & WHITNEY LLP 11 }|Daniel J. Brown, MN Bar No. 0298992 * [email protected] 12||F. Matthew Ralph, MN Bar No. 0323202 * [email protected] 13 150 South Sixth Street, Suite 1500 Minneapolis, MN 55402 14}/Phone 612-343-2183 Fax 612-340-2807 15 || *Admitted pro hac vice 16 || Attorneys for Defendant Deluxe Small Business Sales, Inc. 17 18 The Court finds that the parties have demonstrated good cause to stay discovery. See Schrader v. Wynn, No. 2:19-cv-02159-JCM-BNW,

, (D. Nev. Oct. 14, 2021). So the Court GRANTS their stipulation. IT IS SO ORDERED. 20 21 27 UNITED STATES MAGISTRATE JUDGE 23 DATED: 2/19/2025 24 25 26 27 28