UNITED STATES DISTRICT COURT DISTRICT OF NEVADA CASE NO. 25-CV-00895 SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. JOEL J. NATARIO and JEFFERSON SCOTT (a/k/a “PATCH”) BAKER, Defendants. ________________________________________/ DEFENDANT JOEL NATARIO’S UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT Defendant Joel J. Natario (“Natario”), by and through undersigned counsel, respectfully moves unopposed for an extension of time to answer or otherwise respond to the Complaint filed by the Securities and Exchange Commission (“Plaintiff” or “SEC”), pursuant to Federal Rule of Civil Procedure 6(b) and Local Rule IA 6-1. Natario seeks a 30-day extension of the current deadline of August 25, 2025, through and including September 24, 2025. Counsel for the SEC has confirmed that Plaintiff does not oppose this motion. POINTS AND AUTHORITIES I. BACKGROUND Plaintiff initiated this action by filing its Complaint on May 21, 2025 [ECF No. 1]. On July 15, 2025, Plaintiff, Defendant Jefferson Scott Baker (“Baker”), and Natario filed a Stipulation for Extension of Time [ECF No. 5] by which they all agreed to extend the time for both Baker and Natario to respond to the Complaint through August 25, 2025. This Stipulation was approved by this Court on July 15, 2025 [ECF No. 6]. On July 15, 2025, Plaintiff, Defendant Jefferson Scott Baker (“Baker”), and Natario filed a Stipulation for Extension of Time [ECF No. 5], extending the deadline for both Baker and Natario to respond to the Complaint through August 25, 2025. The Court approved the Stipulation the same day [ECF No. 6]. Subsequently, on August 22, , 2025, Baker filed a motion requesting a 30-day extension

[ECF No. 13], which the Court granted on August 22, , 2025 [ECF No. 14]. On August 25, 2025, the SEC confirmed via email that it does not oppose a corresponding extension for Natario, which would align the response deadlines and case track for both defendants. II. LEGAL ARGUMENTS Good cause exists for the requested extension. Pursuant to Fed. R.Civ. P. 6. “Good cause is a non-rigorous standard that has been construed broadly across procedural and statutory contexts.” See, e.g., Wagers v. Robinson Nev. Mining Co., 3:25-cv-00055-mmd-clb,

, *1 (D. Nev. Apr. 8, 2025). “Requests for extensions of time made before the applicable deadline has passed should normally (…) be granted in the absence of bad faith on the

part of the party seeking relief or prejudice to the adverse party.”

(citing Ahanchian v. Xenon Pictures, Inc.,

, 1259 (9th Cir. 2010)). Here, the undersigned has been unable to finalize Natario’s response due to a medical issue that has limited the ability to confer with him. Additionally, aligning Natario’s response deadline with Baker’s promotes judicial efficiency and consistency in the proceedings. This extension is sought before the applicable deadline, and will not result in prejudice or delay to the proceedings. III. CONCLUSION For the foregoing reasons, Natario respectfully requests that the Court grant this unopposed Motion and extend the deadline to respond to the Complaint through September 24, 2025. Dated this 25th day of August, 2025. Respectfully submitted, /s/ Alejandro O. Soto Alejandro O. Soto, Esq. Florida Bar No. 0172847 FRIDMAN FELS & SOTO, PLLC 150 Alhambra Circle, Suite 715 Coral Gables, FL 33134 Telephone: 305 569 7707 [email protected] BECKSTROM & BECKSTROM, LLP Janes A, Beckstrom, Esq Nevada Bar No. 14032 400 S. 4th Street, Suite 650 Las Vegas, NV 89101 [email protected] Counsel for Defendant Joel J. Natario IT IS SO ORDERED. ______________________________________ U.S. MAGISTRATE JUDGE Date: August 25, 2025