City Boxing Club v. USA Boxing, Inc.

1 || Daniel R. Price (NV Bar No. 13564) Christopher Beckstrom (NV Bar No. 14031) || Janice J. Parker (NV Bar No. 14102) Jasmin N. Stewart (NV Bar No. 16008) || PRICE & BECKSTROM 1404 S. Jones Blvd. || Las Vegas, Nevada 89146 Phone: (702) 941-0503 || Fax: (702) 8382-4026 [email protected] || Attorneys for Plaintiffs 7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA CITY BOXING CLUB, et al., Case No.: 2:23-cv-00708-JAD-DJA = 9 s Plaintiffs, 10 Stipulation and Order to Modify < v. Briefing Schedule Regarding 11 Scottsdale Insurance Company USA BOXING, INC. dba USA BOXING, et | and K&K Insurance Group, Inc.’s 12 al., Motion for Leave to Amend Their 5 Answers to the Second Amended + 13 Defendants. Complaint [ECF No. 80] Plaintiffs, City Boxing Club, City Athletic Boxing LLC, and Armin Van Damme (“Plaintiffs”), and Defendants, USA Boxing, Inc. dba USA Boxing, Scottsdale Insurance Company, Nationwide Mutual Insurance Company, K&K Insurance Group, Inc., hereby stipulate to and respectfully submit their request that the Court extend the time for Plaintiffs to file a response to Plaintiffs’ Opposition to Scottsdale Insurance Company and K&K Insurance Group, Inc.’s Motion for Leave to Amend Their Answers to the Second Amended Complaint (“Motion to Amend”) [ECF No. 80].

21 The Motion to Amend was filed on April 23, 2025, and the response is currently due on May 7, 2025. The parties have been engaged in expert depositions in this matter since |! the Motion to Amend was filed, including the depositions of Plaintiffs’ retained expert || Charles Miller and Defendants Scottsdale Insurance Company’s and K&K Insurance 2. || Group, Inc.’s retained expert Timothy Walker. Accordingly, counsel was required to spend || time preparing for and conducting these depositions in addition to other obligations related || to this matter and other matters.

5 Upon request of Plaintiffs’ counsel, all counsel now submit this stipulation and G request that the Court modify the briefing schedule as stated below. A hearing on the motion has not yet been scheduled.

3 Existing Deadline New Deadline > Plaintiffs’ Response and any May 7, 2025 May 14, 2025 9 Motion to Join — + 10 Reply Brief in Support of May 14, 2025 May 27, 2025 < Motion to Amend w IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: May 7, 2025. Dated: May 7, 2025. + 13 < /s/ Daniel Price □□□ Stephen Hess || Daniel R. Price, Esq. Wing Yan Wong, Esq.

Christopher Beckstrom, Esq. Gordon Rees Scully Mansukhani, LLP || Janice Parker, Esq. 300 S. 4th Street, Suite 1550 Jasmin Stewart, Esq. Las Vegas, NV 89101 || Prick & BECKSTROM 1404 S. Jones Blvd. Stephen A. Hess, Esq.

17 || Las Vegas, Nevada 89146 Law Office of Stephen A. Hess, P.C.

Attorneys for Plaintiffs 111 South Tejon, Suite 102 18 Colorado Springs, CO. 80903 Attorneys for USA Boxing, Inc. || Dated: May 7, 2025.

2 || /s/ Brian Pelanda Christine M. Emanuelson, Esq.

3 || Nicole Hampton, Esq.

Brian L. Pelanda, Esq.

4 || Law Office of Hines Hampton Pelanda LLP || 400 South 4 Street Las Vegas, NV 89101 || Attorneys for Nationwide Mutual Insurance Company, Scottsdale || Insurance Company, and K&K Insurance Group = 9 — ~ 10 DATED: 5/08/2025 IT IS SO ORDERED.

IO Y v ve” \, 2 12 DANIEL J. ALBREGTS 5 UNITED STATES MAGISTRATE + 13 JUDGE