Bilzerian v. Ignite International Brands, LTD.

1 | GARMAN TURNER GORDON LLP ERIC R. OLSEN || Nevada Bar No. 3127 ERIKA PIKE TURNER || Nevada Bar No. 6454 STEVEN E. KISH III || Nevada Bar No. 15257 7251 Amigo Street, Suite 210 || Las Vegas, Nevada 89119 Tel: (725) 777-3000 || Fax: (725) 777-3112 Email: [email protected] 7 [email protected] [email protected] || Attorneys for Defendants Ignite International, Ltd., Scott Rohleder, || and Ignite International Brands, Ltd. 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA || DAN BRANDON BILZERIAN, an individual, | CASE NO.: 2:24-cv-02101-RFB-NJK 13 Plaintiff, 14 V. ORDER TO EXTEND IGNITE || IGNITE INTERNATIONAL BRANDS, INTERNATIONAL BRANDS. LTD.’S LTD., a Foreign Corporation; IGNITE DEADLINE TO FILE RESPONSE TO || INTERNATIONAL, LTD., Foreign PLAINTIFF’S COMPLAINT Corporation, PAUL BILZERIAN, an || individual; SCOTT ROHLEDER, an (FIRST REQUEST) 18 individual; RUPY DHADWAR, an individual, Defendants.

20 Pursuant to Local Rules, Plaintiff, DAN BRANDON BILZERIAN (‘Plaintiff’), and || Defendant, IGNITE INTERNATIONAL BRANDS, LTD. (‘Ignite Brands” or “Defendant”, || together with Plaintiff the “Parties”), through their respective counsel, hereby stipulate and agree || as follows: 24 Ignite shall have until April 24, 2025 to file their responsive pleadings to □□□□□□□□□□□ || Complaint.' | 7 Ges □ Based on the initial Stipulation [ECF 44] lodged on April 15, 2025, Ignite Brands filed a Motion to Dismiss [ECF 47], on April 16, 2025.

1 of 3 1 As required by LR IA 6-1, Defendant’s counsel states that the failure to file the stipulation || to extend before the deadline was the result the attorney’s excusable neglect, and says: 1) there is || no danger of prejudice to the Plaintiff, especially in light of pending motions to dismiss by all other || Defendants; 2) there is no impact due to a seven day delay between the deadline and the filing; 3) || the reason for the delay was counsel’s misapprehension that the only attempted service on the || Canadian company had been disputed the service in Texas until Plaintiff's counsel confirmed on || April 10, 2025, re-service occurred in Canada on March 18, 2025 (making the responsive pleading || due April 8") and agreed to an extension until April 24,2025 (although Plaintiffs counsel would || not return to his office on April 14, 2025), and both counsel agreed to the stipulation to extend on || April 14"", which Defendant’s counsel lodged with the Court on April 15, 2025; 4) Defendant acted || in good faith and without any intent to delay.”

12 Plaintiff takes no position on excusable neglect and expressly reserves all rights, remedies, || defenses, objections, and legal arguments. Plaintiff also contends that service in Texas was valid; || however, out of abundance of caution, he decided to re-serve the Defendant in Canada.

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28 ? See, Briones v. Riviera Hotel & Casino, 116 F.3d 379, 381 (9th Cir. 1997).

9% of 3 This is the Parties’ first request for extension of time this deadline, and it is not intended to || cause any delay or prejudice to any party.

3 IT IS SO STIPULATED.

4 || Dated this 18"* day of April 2025. Dated this 18" day of April 2025.

5 GARMAN TURNER GORDON LLP THE MEDRALA LAW FIRM, PROF. LLC 6 /s/ Eric R. Olsen [s/ Jakub P. Medrala 7 ERIC R. OLSEN JAKUB P. MEDRALA Nevada Bar No. 3127 Nevada Bar No. 12822 8 ERIKA PIKE TURNER 615 S. 6th Street Nevada Bar No. 6454 Las Vegas, Nevada 89101 9 STEVEN E. KISH II Attorneys for Plaintiff Nevada Bar No. 15257 10 7251 Amigo Street, Suite 210 Las Vegas, Nevada 89119 11 Attorneys for Defendants Ignite International, Ltd., Scott Rohleder, 12 and Ignite International Brands, Ltd. 17 ORDER 1 IT IS SO ORDERED: 2 Nancy J. Re She ) United States Magistrate Judge 2 DATED: April 21, 2025 3o0f3