1 John D. Tennert, III, NV Bar No. 11728 Austin W. Slaughter, NV Bar No. 15645 2 FENNEMORE CRAIG, P.C. 7800 Rancharrah Parkway 3 Reno, NV 89511 Telephone: (775) 788-2200 4 Facsimile: (775) 788-2279 [email protected] 5 [email protected] 6 Attorneys for All Americas International, Inc. 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 ABORNES INTERNATIONAL, INC., CASE NO. 3:24-cv-00100-ART-CSD 10 Plaintiff, vs. 11 STIPULATION AND ORDER TO 12 ALL AMERICAS INTERNATIONAL, INC., EXTEND DISCOVERY DEADLINES Defendant. 13 (SIXTH REQUEST) 14 15 Plaintiff Abornes International Inc. (“Plaintiff”) and Defendant All Americas International, 16 Inc. (“Defendant”) by and through their undersigned counsel of record stipulate to extend the 17 deadlines in the scheduling order pursuant to LR 26-3 with the Court’s approval. This is the 18 parties’ sixth request in this litigation to extend said deadlines. The current scheduling order is on 19 file herein as ECF No. 58. Based on outstanding discussions regarding discovery and scheduling 20 logistics for purposes of depositions, the parties respectfully request the Court to grant the 21 requested extension. 22 I. Good cause exists to extend the existing discovery deadlines by sixty days. 23 The Court has broad discretion in supervising the pretrial phase of litigation, which 24 includes modifying its scheduling orders. Zivkovic v. S. California Edison Co.,

, 25 1087 (9th Cir. 2002). In order for the Court to grant a motion or stipulation to modify a 26 scheduling order, and extend the unexpired deadlines provided therein, the motion or stipulation 27 must be supported by good cause, and it must satisfy the requirements of LR IA 6-1. Fed. R. Civ. P. 16(b)(4); Local Rule 26-3. The good cause analysis depends on whether the subject deadlines 1 cannot reasonably be met despite the exercise of diligence. Johnson v. Mammoth Recreations, 2 Inc., 90-15975,

(9th Cir. 1992) (citing Fed.R.Civ.P. 16 advisory committee’s 3 notes (1983 amendment)). Additionally, a motion or stipulation to extend discovery deadlines 4 must include: (a) a statement specifying the discovery completed; (b) a specific description of the 5 discovery that remains to be completed; (c) the reasons why the deadline was not satisfied or the 6 remaining discovery was not completed within the time limits set by the discovery plan; and (d) a 7 proposed schedule for completing all remaining discovery. Local Rule 26-3(a)-(d). 8 A. Brief procedural history 9 This case was initiated by Plaintiff on February 28, 2024, and Defendant filed its answer 10 on April 30, 2024. The parties have exchanged initial disclosures, and Plaintiff served its first set 11 of written discovery requests on June 10, 2024. Plaintiff also served supplemental requests, to 12 which Defendant responded on January 6, 2025. 13 On April 18, 2025, Defendant noticed the deposition of Abornes’ FRCP Rule 30(b)(6) 14 designee for May 8, 2025, but the deposition was rescheduled due to Plaintiff and Plaintiff’s 15 counsel’s unavailability. On June 5, 2025, Defendant served a deposition notice for Abornes’ 16 director, Ingrid Vanessa Sucre, setting the deposition for June 27, 2025. Subsequently, on June 13, 17 2025, Defendant served an amended Rule 30(b)(6) notice setting Abornes’ deposition for June 30, 18 2025. However, Plaintiff’s counsel advised that he would be in trial in London from late June 19 through the July 14 discovery deadline, and the parties agreed to reset both Ms. Sucre’s and 20 Abornes’ Rule 30(b)(6) depositions to mutually available dates. These depositions were noticed 21 for August 13 and 14, 2025, and subsequently re-noticed for September 26 and 29, 2025. 22 In addition, Plaintiff has requested the deposition of Defendant’s current Director, John 23 Forsyth, and seeks to reopen the deposition of AAI’s Rule 30(b)(6) witness, subject to the parties’ 24 agreement. 25 The parties met and conferred on September 17, 2025 and September 22, 2025 to address 26 scheduling and negotiate dates for these remaining depositions. 27 Due to Defendant’s request to take the deposition of Ms. Sucre—a Panamanian national 1 notice of its intent to reopen the deposition of AAI’s Rule 30(b)(6) witness, John Cronin, as well 2 as to proceed with the deposition of Defendant’s Director, John Forsyth, the parties—though 3 initially optimistic about completing all depositions before the end of September—now believe 4 that scheduling these remaining depositions may extend into November. Accordingly, the parties 5 respectfully request that discovery remain open for the limited purpose to complete the deposition 6 process. 7 All parties agree that extending the deadlines in the Scheduling Order, as described herein, 8 is appropriate and should be approved. 9 B. Discovery completed 10 Good cause exists to modify the existing scheduling order and extend the discovery 11 deadlines by sixty days. As a preliminary matter, to date, all parties have engaged in multiple 12 rounds of written discovery in the form of written interrogatories and requests for production of 13 documents. All parties have likewise received written responses to those requests and each side 14 has produced several tens of thousands of documents. Specifically, the parties have completed the 15 following: 16 1. Discovery Completed by Plaintiff 17 Date Description Response 18 May 28, 2024 Plaintiff’s Fed. R. Civ. P. 26(a)(1) Initial Disclosures N/A 19 June 10, 2024 Plaintiff’s First Set of Interrogatories to Defendant July 13, 2024 June 10, 2024 Plaintiff’s First Set of Requests for July 13, 2024 20 Production of Documents 21 December 6, 2024 Plaintiff’s Second Set of Requests for Production January 6, 2025 of Documents 22 December 6, 2024 Plaintiff’s Second Set of Interrogatories to January 6, 2025 Defendant 23 June 24, 2025 Plaintiff’s Requests for Admission July 24, 2025 24 25 / / / 26 / / / 27 / / / / / / 1 2. Discovery Completed by Defendant 2 Date Description Response May 30, 2024 Defendants’ Fed. R. Civ. P. 26(a)(1) N/A 3 Initial Disclosures 4 September 20, 2024 Defendant’s First Set of Interrogatories to Plaintiff October 24, 2024 5 September 20, 2024 Defendant’s First Set of Requests for October 24, 2024 6 Production of Documents June 13, 2025 Defendant’s Second Set of Requests for July 13, 2025 7 Production of Documents 8 June 13, 2025 Defendant’s Second Set of Interrogatories to July 13, 2025 Plaintiff 9 June 13, 2025 Defendant’s Requests for Admission July 13, 2025 10 11 C. Depositions. 12 Plaintiff deposed Defendant’s Rule 30(b)(6) representative, John Cronin, on February 10, 13 2025. The parties are currently meeting and conferring regarding the scope, topics, and terms for 14 the continuation of Mr. Cronin’s Rule 30(b)(6) deposition. They are working to schedule the 15 continued deposition during October or November. The parties are also coordinating to determine 16 the availability of Ingrid Vanessa Sucre, a Director of Abornes and designated Rule 30(b)(6) 17 representative, for deposition, including the possibility of having this deposition over Zoom In 18 addition, the parties are continuing to meet and confer regarding the deposition of Defendant’s 19 Director, John Forsyth. 20 D. Discovery that remains to be completed. 21 As noted above, a brief extension is requested due to the parties’ unavailability to conduct 22 the noticed depositions within the current discovery period. The scheduling conflicts and ongoing 23 discussions about the scope and terms of the depositions have necessitated the extension. 24 E. Reasons why the Remaining Deadlines Should be Moved Approximately Sixty (45) 25 Days. 26 Under LR 26-3, motions or stipulations to extend discovery must be filed at least 21 days 27 before the applicable deadline. The current discovery deadline is Septembre 29, 2025, and this 1 request is being made within the 21-day window. The delay is due to the parties’ ongoing, good 2 faith efforts to coordinate mutually agreeable dates and locations for the remaining depositions 3 and the possibility of having the remaining depositions over Zoom. These include Plaintiff’s 4 Rule 30(b)(6) deposition, the deposition of Ms. Sucre (a Panamanian national), and a continued 5 deposition of Defendant’s Rule 30(b)(6) representative, John Cronin, based on documents 6 produced after his initial deposition that Plaintiff believes are relevant to a complete 7 examination. The parties also continue to meet and confer regarding the deposition of 8 Defendant’s Director, John Forsyth. 9 This request is made jointly and in good faith, and not for purposes of delay. A trial date 10 has not been set. The requested extension is limited to 60 days and is not expected to prejudice 11 either party. The extension is sought solely to allow the parties adequate time to complete 12 necessary depositions. 13 This is the sixth extension request. However, each request has been related to the same 14 ongoing discovery issues, which the parties are working to resolve cooperatively and without 15 further Court involvement. The parties believe the reasons outlined above constitute good cause 16 for the requested extension. 17 F. Proposed New Schedule: 18 Event Current Deadline Proposed Deadline 19 Close of Discovery September 29, 2025 December 1, 2025 20 21 22 23 24 25 26 27 1 | IT IS SO STIPULATED. 2 || Dated this 25th day of September, 2025. Dated this 25th day of September 2025. 3 || FENNEMORE CRAIG, P.C. HOLLAND & KNIGHT LLP 4 By:_/s/ John D. Tennert By: /s/ James H. Power 5 . John D. Tennert (Nev. Bar No. 11728) James H. Power (pro hac vice) 6 || Austin W. Slaughter (Nev. Bar No. 15645) Anjuli B. Woods (Nev. Bar No. 10989) Rancharrah Parkway HOLLAND & KNIGHT LLP 787 7 || Reno, NV 89511 Seventh Avenue jtennert @fennemorelaw.com New York, New York, 10019 8 || [email protected] [email protected] 9 || Attorneys for Defendant, All Americas Inc. Anjuli, woods @hklaw.com 10 Ryan J. Works, Esq. (Nev. Bar No. 9224) Phillip M. Mannelly, Esq. (Nev. Bar No. 142: 11 100 W. Liberty Street, Tenth Floor D Reno, Nevada 89501 rworks @mcdonaldcarno.com 13 pmannelly @ mcdonaldcarano.com 14 Attorneys for Plaintiff Abornes 15 16 IT ISSO ORDERED. CS 18 UNITED STATES M TRATE JUDGE 19 DATED: September 26, 2025 21 22 23 24 25 26 27 28 CRAIG