Federal Trade Commission v. International Markets Live, Inc.

1 Phillip A. Silvestri, Esq.

Nevada Bar No. 11276 [email protected] GREENSPOON MARDER LLP 3993 Howard Hughes Pkwy., Ste. 400 Las Vegas, Nevada 89169 Tel: (702) 978-4249 Fax: (954) 333-4256 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA FEDERAL TRADE COMMISSION, and CASE NO.: 2:25-cv-760-CDS-NJK STATE OF NEVADA, 11 Plaintiff, v. UNOPPOSED MOTION TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSE AND/OR ANSWER TO INTERNATIONAL MARKETS LIVE, PLAINTIFFS’ COMPLAINT INC., et al.

15 [First Request] Defendants.

16 ______________________________________/ Defendants Global Dynasty Network, LLC. (“Global Dynasty”) and Matthew Rosa (““Rosa” and together with Global Dynasty, “Defendants”), by through counsel, hereby move for an extension of time of thirty-four (34) days to file and serve a response and or answer to the Plaintiff's Complaint (ECF No. 1), which is currently due on May 27, 2025, through and including July 7, 2025. The undersigned counsel for Defendants also represents Defendant Jason Brown (“Brown”), whose response date is also July 7, 2025, such that the granting of this motion will result in all three Defendants have the same deadline by which to answer or respond to the Complaint.

8 Fed. R. Civ. P. 6(b) provides that the Court, for good cause, may extend the time to answer or otherwise respond to the Complaint. See also United States v. Alpine Sec. Corp., No. 2:22-CV-01279- 10 RFB-VCF, 2023 WL 8653135, at *1 (D. Nev. Dec. 14, 2023). Here, Defendants’ motion is timely, and is made before the time in which they have to answer the Complaint has expired. Defendants make 12 the motion in anticipation that all Defendants represented by the undersigned might consolidate their 13 responses to the Complaint, thus servicing efficiency purposes for the case. This motion is made in good faith and not for purposes of improper delay. On May 23, 2025, counsel for Defendants conferred 1S with counsel for Plaintiffs. Counsel for Plaintiffs stated they did not oppose the relief requested herein.

Dated: May 27, 2025. Respectfully submitted, 18 GREENSPOON MARDER LLP 19 /s/Phillip Silvestri PHILLIP SILVESTRI 20 Nv. Bar No. 11276 Email: [email protected] 21 GREENSPOON MARDER LLP 9 3993 Howard Hughes Parkway, Suite 400 IT 1S SO ORDERED. Las Vegas, NV 89159 || Dated: May 28, 2025 Tel: (702) 978-4249 |) 2 fo fo Attorneys for Defendants Jason Nancy J. Kop ye Brown, Matt Rosa, and Global Dynasty || United States Magistrate Judge Network, LLC Page 2 of 3