1 Kevin M. Sutehall, Bar No. 009437 Jonathan R. Lagarenne (pro hac vice) Mark J. Connot, Bar No. 010010 FOX ROTHSCHILD LLP 2 FOX ROTHSCHILD LLP 212 Carnegie Center, Suite 400 1980 Festival Plaza Dr., Suite 700 Princeton, New Jersey 08540 3 Las Vegas, Nevada 89135 Phone: 609-896-3600 Phone: 702-262-6899 Fax: 609-896-1469 4 Fax: 702-597-5503 Email: [email protected] Email: [email protected] 5 Email: [email protected] 6 Attorneys for Defendants, Jushi NV, Inc., NuLeaf Incline Dispensary, LLC, Nuleaf CLV Dispensary, LLC 7 and NuLeaf Clark Dispensary, LLC 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 NULEAF NATURALS, LLC, a Colorado Case No. 2:24-cv-02075-CDS-DJA Limited Liability Company, 12 Plaintiff, 13 STIPULATION TO STAY DISCOVERY v. AND AMEND SCHEDULING ORDER 14 PENDING SETTLEMENT JUSHI NV, INC., a Delaware Corporation; NEGOTIATIONS 15 NULEAF INCLINE DISPENSARY, LLC, a Nevada Limited Liability Company; NULEAF (FIRST REQUEST) 16 CLV DISPENSARY, LLC, a Nevada Limited Liability Company; and NULEAF CLARK 17 DISPENSARY, LLC, a Nevada Limited Liability Company, 18 Defendants. 19 20 Pursuant to Federal Rules of Civil Procedure 16(b)(4) and 26(c), and Local Rules 7-1 and 21 26-3, Plaintiff NuLeaf Naturals, LLC (“NuLeaf” or “Plaintiff”) and Defendants, Jushi NV, Inc., 22 NuLeaf Incline Dispensary, LLC, NuLeaf CLV Dispensary, LLC and NuLeaf Clark Dispensary, 23 LLC (collectively, “Jushi” or “Defendants,” together with Plaintiff the “Parties”), by and through 24 their respective undersigned counsel of record, hereby stipulate and respectfully request that the 25 court stay discovery and amend the Stipulated Discovery Plan and Scheduling Order (as Amended) 26 entered in the above action. (ECF 26). In support thereof, the Parties state as follows: 27 28 1 1. On December 3, 2024, the Court granted the Parties’ Stipulation to Extend Deadline 2 to Respond to Plaintiff’s Complaint for Injunction for Trademark Infringement (First Request) 3 (ECF No. 16). 4 2. On January 3, 2025, Defendants filed their Answer to Plaintiff’s Complaint and 5 Counterclaims (ECF No. 17). 6 3. On January 24, 2025, the Court granted the Parties’ Stipulation to Extend Time to 7 Answer or Otherwise Respond to the Counterclaim (First Request) (ECF No. 19). 8 4. On January 28, 2025, Plaintiff filed its Answer to Defendants’ Counterclaims (ECF 9 No. 20). 10 5. On February 18, 2025, Defendants filed their Amended Answer to Complaint; and 11 Counterclaims. (ECF No. 24). 12 6. On Feburary 25, 2025, the Court granted in part and denied in part the Parties’ 13 Discovery Plan and Scheduling Order. (ECF No. 26). 14 7. On March 4, 2025, Plaintiff filed its Answer to Amended Counterclaims. (ECF No. 15 27), 16 8. On May 7, 2025, Plaintiff filed an Unopposed Motion to Amend Complaint. (ECF 17 No. 28). 18 9. On May 8, 2025, the Court, granted Plaintiff’s Motion to Amend Complaint, ordered 19 Plaintiff to file and serve the amended complaint (ECF No. [28-1]) as required by Local Rule 15- 20 1(b). (ECF No. 29). 21 10. On May 9, 2025, Plaintiff filed its First Amended Complaint and the parties have 22 agreed that Defendant will answer within twenty (20) days after Plaintiff declares settlement 23 negotiations finished or at an impasse. 24 11. No trial date has been set in this matter. 25 12. The parties are actively engaged in good faith settlement negotiations to resolve this 26 matter without further litigation. The parties believe that a temporary stay of discovery and 27 modification of the scheduling order will conserve judicial resources and the parties’ resources by 28 avoiding unnecessary discovery costs during these discussions. 1 13. The Parties submit that good cause exists for this request, as settlement negotiations 2 are ongoing, and a stay will promote efficiency and potentially resolve the case without further 3 court intervention. The parties have conferred and agree that a stay of discovery for 60 days is 4 appropriate to focus on settlement efforts. 5 14. Courts have “broad discretionary power to control discovery.” Miller v. Republic 6 Silver State Disposal, Inc.,

, at *1 (D. Nev. Sept. 19, 2022) (citing Little v. City 7 of Seattle,

(9th Cir. 1988)). Consistent with that discretion and particularly when 8 the parties stipulate, this Court stays discovery when good cause exists and the pending motion can 9 be decided without further discovery. Id. at *1-2; see also, e.g., Bloom v. Zuffa, LLC.,

6197341, at *4 (D. Nev. Sept. 22, 2023). 11 15. The Parties request that the Court (a) stay all discovery obligations, including but 12 not limited to depositions, written discovery, and expert disclosures, for a period of 60 days from 13 the date of this Court’s Order; (b) extend all deadlines in the current Scheduling Order (ECF No. 14 26)including discovery cutoff, motion deadlines, and other related dates, by 60 days or as the Court 15 deems appropriate; and (c) require the Parties to file a Joint Status Report 30 days from the date of 16 this Order to update the Court on the status of settlement negotiations. 17 16. This stipulation is not intended to cause delay or prejudice any party’s rights or 18 defenses and is entered into solely to facilitate settlement discussions. 19 WHEREFORE, the Parties respectfully request that the Court grant this stipulation and 20 enter an order staying discovery and amending the scheduling order as set forth above. 21 22 23 [Signature block and proposed order on following page.] 24 25 26 27 28 1 5 DATED: July 23, 2025 DATED: July 23, 2025

3 FOX ROTHSCHILD LLP SEMENZA RICHARD LAW ‘ /s/ J. Mark Smith /s/ Mark J. Connot Bh ON 5 | KEVIN M. SUTEHALL (SBN 009437) OP ae Rory □ MARK J. CONNOT (SBN 010010) L va. 6 . . as Vegas, Nevada 89145 1980 Festival Plaza Dr., Suite 700 Email: [email protected] 4 Las Vegas, Nevada 89135 “J , Email: [email protected] . . J. Mark Smith, Esq. (pro hac vice) g Email: [email protected] FAIRFIELD AND WOODS, P.C. Jonathan R. Lagarenne (pro hac vice) 1801 California Street, Suite 2600 9 | FOX ROTHSCHILD LLP Denver, Colorado 80202 . . Email: [email protected] 212 Carnegie Center, Suite 400 Attorneys for Plaintiff 10 Princeton, New Jersey 08540 y me Email: [email protected] 11 Attorneys for Defendants 12 || IT IS THEREFORE ORDERED that the parties’ stipulation (ECF No. 31) is granted in part 3 and denied in part. It is granted in part regarding the parties' request for a stay of discovery and for the Court to require them to file a joint status report. It is denied in part regarding the parties’ 14 |} request for an extension of discovery deadlines. 15 || 1T IS FURTHER ORDERED that discovery is stayed until September 22, 2025. 16 IT IS FURTHER ORDERED that the parties must file a joint status report regarding the status 17 || of their settlement negotiations on or before September 22, 2025. Ifthe parties need additional time for their negotiations, they must also stipulate to extend the stay. If the parties' wish to 18 || move forward with discovery, they must also stipulate to extend discovery deadlines. 19 20 71 DANIEL J. ALBREGTS 02 UNITED STATES MAGISTRATE JUDGE 23 DATED: July 24, 2025 24 25 26 27 28