1 JASON M. WILEY, ESQ. Nevada Bar No. 9274 2 E.DANIEL KIDD, ESQ. Nevada Bar No. 10106 3 WILEY PETERSEN 10000 W. Charleston Blvd., Suite 230 4 Las Vegas, Nevada 89135 Telephone: 702.910.3329 5 Facsimile: 702-553-3467 [email protected] 6 [email protected] 7 Attorneys for Plaintiffs 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 APEX OPERATIONS, LLC, a Nevada limited liability company; 420702 CONSULTING, LLC, a CASE NO.: 2:22−cv−01169−RFB−DJA 11 Nevada limited liability company; ZOHA DEVELOPMENT, LLC, a Nevada limited liability 12 company; MACMAS REAL ESTATE AND AGRICULTURAL PRIVATE EQUITY STIPULATION AND ORDER TO 13 OPPORTUNITY FUND, LLC a foreign country EXTEND DISCOVERY DEADLINES limited liability company; MICHAEL SASSANO, [THIRD REQUEST] 14 an individual; RONALD SASSANO, an individual, 15 Plaintiffs, 16 v. 17 PAVEL ROSENBERG, and individual; MCIG, 18 INC., a Wyoming corporation; BOTS, INC. a Puerto Rico corporation; OBITX, INC., a foreign 19 corporation; DOE individuals I through X, inclusive; and ROE entities I through X, inclusive, 20 Defendants. 21 22 23 Pursuant to Local Rule 26-3, Plaintiffs APEX OPERATIONS, LLC, 420702 CONSULTING, 24 LLC, ZOHA DEVELOPMENT, LLC, MACMAS REAL ESTATE AND AGRICULTURAL PRIVATE 25 EQUITY OPPORTUNITY FUND, LLC, MICHAEL SASSANO, and RONALD SASSANO 26 (collectively, “Plaintiffs”) and Defendant PAVEL ROSENBERG, stipulate to extend the deadlines in 27 Stipulation And Order To Extend Discovery Deadlines [Second Request] [ECF No. 49] adopted by the Court on May 6, 2025. As provided herein, good cause supports this request. 1 I. The completed discovery. 2 A. Discovery completed by Plaintiffs 3 1. Written Discovery and Disclosures 4 Date Description Response 5 7.17.2024 Plaintiffs’ Initial Disclosures Pursuant to N/A Fed.R.Civ.P. 26(a)(1) 6 8.1.2024 Plaintiff Apex Operations, LLC’s First Set of Responses received: 7 Requests for Admissions to Defendant Pavel 10.1.2024 Rosenberg 8 8.1.2024 Plaintiff Apex Operations, LLC’s First Set of Responses received: 9 Interrogatories to Defendant Pavel Rosenberg 10.23.2024 10 8.1.2024 Plaintiff Apex Operations, LLC’s First Set of Responses received: Requests for Production of Documents to Defendant 10.23.2024 11 Pavel Rosenberg 12 1.31.2025 Plaintiff Apex Operations, LLC’s Supplemental Responses received: Requests for Production of Documents to Defendant 5.20.2025 13 Pavel Rosenberg 14 1.31.2025 Plaintiff Apex Operations, LLC’s Supplemental Responses received: Interrogatories to Defendant Pavel Rosenberg 5.20.2025 15 1.31.2025 Plaintiff Apex Operations, LLC’s Second Set of Responses received: 16 Requests for Admissions to Defendant Pavel 5.20.2025 Rosenberg 17 18 2. Subpoenas 19 Date Description Recipient 20 8.6.2024 Subpoena to Produce Documents Securities Transfer Corporation 21 8.6.2024 Subpoena to Produce Documents Island Stock Transfer 22 8.6.2024 Subpoena to Produce Documents Wilson-Davis & Company 23 8.28.2024 Subpoena to Produce Documents Visa USA, Inc. 24 8.28.2024 Subpoena to Produce Documents Fidelity Brokerage Services, LLC a/k/a Fidelity Investments f/k/a Fidelity 25 Management & Research 26 8.28.2024 Subpoena to Produce Documents Merrill Lynch, Pierce, Fenner & Smith, Inc. 27 8.28.2024 Subpoena to Produce Documents JP Morgan Chase & Co. 1 9.25.2024 Subpoena to Produce Documents Island Capital Group, LLC d/b/a Island Stock Transfer 2 1.30.2025 Subpoena to Produce Documents Visa USA, Inc. 3 1.30.2025 Subpoena to Produce Documents Fidelity Brokerage Services, LLC a/k/a 4 Fidelity Investments f/k/a Fidelity Management & Research 5 1.30.2025 Subpoena to Produce Documents JP Morgan Chase Bank, N.A. 6 1.30.2025 Subpoena to Produce Documents J.P. Morgan Securities LLC 7

8 Plaintiffs’ claims and causes of action arise from a certain Settlement Agreement and Mutual 9 Release (“Settlement Agreement”) entered into and executed by and between Plaintiffs, on the one 10 hand, and Defendant Pavel Rosenberg (“Rosenberg”) on the other. Plaintiffs’ Complaint alleges, in 11 pertinent part: 12 Agreement Payment Obligations to Plaintiff Apex O 13 17. The Agreement expressly provides that “[i]n full satisfaction of any and all claims 14 asserted by the Parties, MCIG and PR [defined as Defendant Rosenberg] personally shall pay a total 15 sum of Four Hundred Eighty-Three Thousand and 00/100 Dollars ($483,000.00) (U.S.) (“Settlement 16 Amount”) to Apex O. 17 18. Section 3 of the Agreement provides for the payment terms of the Settlement Amount 18 which provide, in pertinent part, that installment payments were to begin on October 5, 2019, and 19 continue thereafter on the 1st of each subsequent month until paid in full, with said installment payments 20 in the amount of either Twenty Thousand Dollars ($20,000.00) or Forty Thousand Dollars ($40,000.00) 21 depending on the then-price of MCIG stock shares. 22 19. The Agreement further states that failure by MCIG and Rosenberg to tender any of the 23 installment payments when due constitutes a default and, pursuant to Section 9 of the Agreement, such 24 default causes the Settlement Amount to increase to Five Hundred Eighty-Three Thousand Dollars 25 ($583,000.00). 26 20. From October 2019 through June 2020, MCIG and Rosenberg remit nine (9) installment 27 payments in the total amount of One Hundred Forty-Eight Thousand Dollars ($148,000.00) to Apex O. 1 21. Thereafter, MCIG and Rosenberg failed to tender any additional payments thus 2 defaulting on the repayment terms and conditions set forth in the Agreement and causing the Settlement 3 Amount to increase One Hundred Thousand Dollars ($100,000.00) as provided in Section 9 of the 4 Agreement and detailed herein. 5 22. The principal amount of Four Hundred Thirty-Five Thousand Dollars ($435,000.00) 6 remains due and owing to Apex O from MCIG and Rosenberg. 7 Agreement Payment Obligations to Zoha and MacMas 8 23. Section 4 of the Agreement provides that MCIG and Rosenberg, personally, agreed to 9 release (i) as free trading shares in the amount of 500,000 common stock shares of MCIG in the name of 10 Zoha; and (ii) 11,000,000 common stock shares of MCIG in the name of MacMas. 11 24. While the shares were released, MCIG – which at some point after execution of the 12 Agreement was rebranded as BTZI – failed to file certain returns in a timely manner which precluded 13 MacMas and R. Sassano from trading shares from August 25, 2022, through June 7, 2021 (the 14 “Restricted Period”). 15 25. Rosenberg served as the MCIG/BTZI Chief Executive Officer at all times while MacMas 16 and R. Sassano were prevented from trading shares. 17 26. The preclusion of MacMas and R. Sassano from trading shares constitutes a default 18 pursuant to the terms and conditions of the Agreement. 19 27. During the Restricted Period, BTZI shares were consistently trading at $0.15/share. 20 28. Once the Restricted Period lapsed and MacMas and R. Sassano were allowed to actively 21 sell its BTZI shares, the value of those shares had dropped precipitously. 22 29. From June 8, 2021, through March 18, 2022, BTZI’s average daily high value was 23 $0.52/share – almost $.10 less than the average share value during the Restricted Period. 24 30. MacMas and R. Sassano sold approximately 2,000,000 BTZI shares at a value far less 25 than they would have if allowed to sell shares during the Restricted Period. 26 31. Since execution of the Agreement, Rosenberg has resigned all positions with 27 MCIG/BTZI and gave back a block of shares of those entities to capital stock. 1 32. Further, upon information and belief, since Rosenberg’s resignation of all positions with 2 MCIG/BTZI, he has acquired a substantial amount of shares of OBITX stock. 3 Defendant Rosenberg relies upon language in the Settlement Agreement as a defense to the 4 allegations Plaintiffs assert against him. Specifically, Section 2 of the Agreement provides “[t]he 5 Parties understand and agree that the extent of PR [Rosenberg’s] personal liability for this entire amount 6 of $483,000, his only encumbering asset(s) will be PR’s shares he owns of MCIG and any monies 7 transferred or in bank or brokerage or others from selling MCIG shares after signing this settlement, and 8 no other personal liability exists.” 9 Depositions 10 Date Description Recipient 11 2.7.2025 Subpoena to Testify at a Deposition Pavel Rosenberg 12 8.15.2025 Subpoena to Testify at a Deposition Pavel Rosenberg 13 14 On February 7, 2025, Plaintiffs noticed the deposition of Defendant Rosenberg for February 28, 15 2025. On February 10, 2025, Rosenberg’s counsel sent correspondence indicating that Rosenberg was 16 not available on that date, that Defendant was interested in noticing the depositions of Plaintiffs’ 17 representatives, and that the parties would coordinate on availability. At this time, Rosenberg was still 18 dealing with health issues that precluded his participation in the deposition process. 19 Thereafter, on February 28, 2025, Plaintiffs’ counsel sent follow-up correspondence to 20 Rosenberg’s counsel requesting a call to discuss scheduling of depositions and coordination of effort. 21 Rosenberg’s counsel responded on March 4, 2025, and the parties participated a telephone 22 conference thereafter wherein Rosenberg’s counsel indicated he was still working on dates and 23 transportation logistics related to the deposition. 24 On April 10, 2025, Plaintiffs’ counsel sent a follow-up correspondence regarding Rosenberg’s 25 deposition and outstanding discovery. Counsel participated in a telephone conference thereafter and 26 realized the need to stipulate to extend discovery deadlines to complete the outstanding discovery 27 matters. 1 On August 8, 2025, Rosenberg’s counsel provided supplemental discovery responses and 2 documents to Plaintiffs’ counsel. Thereafter, Plaintiffs re-noticed Rosenberg’s deposition for August 3 25, 2025. 4 On August 22, 2025, Rosenberg’s counsel contacted Plaintiffs’ counsel and indicated that 5 Rosenberg was unavailable for deposition on August 25, 2025. Further, in that Rosenberg did not reside 6 in the United States, Rosenberg would be unavailable for deposition until October 10, 2025, through 7 October 30, 2025, when he would return to the United States. Plaintiffs’ counsel indicated that 8 Rosenberg is willing and available to be deposed during that time window. The parties have agreed to 9 find a date in late October to conduct the deposition. 10 Based upon the foregoing, Plaintiffs anticipate re-noticing the deposition of Rosenberg and have 11 no issue with Defendant conducting the depositions of Plaintiffs’ representatives to ensure the litigation 12 can be heard on its merits. 13 B. Discovery completed by Defendants 14 1. Written Discovery and Disclosures 15 Date Description Response 16 10.24.2024 Defendant Pavel Rosenberg’s First Set of Responses received: Interrogatories to Plaintiffs Michael Sassano and 2.21.2025 17 Ronald Sassano 18 10.24.2024 Defendant Pavel Rosenberg’s First Set of Requests Responses received: for Production of Documents to Plaintiffs Michael 2.21.2025 19 Sassano and Ronald Sassano 20 2. Subpoenas 21 None. 22 3. Depositions 23 None. 24 II. Discovery that remains to be completed. 25 Deposition of Pavel Rosenberg 26 Deposition of Michael Sassano 27 Deposition of Ronald Sassano 1 The parties anticipating noticing the depositions of certain witnesses listed – or to be listed – in 2 each other’s disclosures, including percipient witnesses and Rule 30(b)(6) representatives. 3 Subpoenas issued to stock brokerages for sales of relevant shares owned by Michael Sassano and 4 Ronald Sassano. 5 Potential for expert and rebuttal expert disclosures/depositions 6 III. The reasons why the remaining discovery was not completed within the time limits 7 imposed by the discovery plan 8 The parties submitted a proposed discovery plan in late May-2024 and the Court adopted the 9 parties’ plan on July 10, 2024. Almost immediately thereafter, Plaintiffs served their initial disclosures 10 and propounded discovery on Rosenberg on August 1, 2024. On August 13, 2024, Rosenberg’s counsel 11 contacted Plaintiffs’ counsel requesting an additional 30 days to respond to the discovery requests due to 12 Defendant undergoing a medical procedure in late-August, 2024. Plaintiffs’ counsel granted the request 13 and the responses were served in October 2024. 14 Based upon information gleaned during those responses, perceived deficiencies in the responses, 15 and additional information learned from third-party subpoenas, Plaintiffs served a second set of 16 discovery requests on Rosenberg on January 31, 2025, with a notice setting Rosenberg’s deposition for 17 February 28, 2025. Due to Rosenberg’s continued health issues and logistics of Rosenberg’s travel to 18 Las Vegas to participate in the deposition, Rosenberg has been unable to properly respond to the 19 propounded discovery and has not provided Plaintiffs with a date for the rescheduled deposition. 20 On August 8, 2025, Rosenberg’s counsel provided supplemental discovery responses and 21 documents to Plaintiffs’ counsel. Thereafter, Plaintiffs re-noticed Rosenberg’s deposition for August 22 25, 2025. 23 On August 22, 2025, Rosenberg’s counsel contacted Plaintiffs’ counsel and indicated that 24 Rosenberg was unavailable for deposition on August 25, 2025. Further, in that Rosenberg did not reside 25 in the United States, Rosenberg would be unavailable for deposition until October 10, 2025, through 26 October 30, 2025, when he would return to the United States. Plaintiffs’ counsel indicated that 27 Rosenberg is willing and available to be deposed during that time window. The parties have agreed to 1 Local Rule 26-3 governs modifications or extensions of the scheduling order. Pursuant to LR 2 26-3, any motion or stipulation to extend discovery must be received by the Court “no later than twenty- 3 one (21) days before the expiration of the subject deadline.” LR 26-3 further states that “a request made 4 within 21 days of the subject deadline must be supported by a showing of good cause.” 5 The parties recognize that they are requesting an extension of certain deadlines within 21 days of 6 the expiration. As such, the parties submit that, based on the good cause exists to permit granting the 7 instant requested extension. In evaluating “good cause” this Court has held “[t]he ‘good cause’ standard 8 in Local Rule 26-3 is the same as the standard governing modification of the scheduling order under 9 Fed.R.Civ.P. 16(b).” Tanya Victor v. Walmart, Inc., No. 2:20-cv-0101591,

, at *2 10 (D. Nev. Apr. 8, 2021). Good cause to extend the discovery deadlines is found where “it cannot 11 reasonably be met despite the diligence of the party seeking the extension.” Johnson v. Mammoth 12 Recreations, Inc.,

(9th Cir. 1992). 13 In the present matter, as noted, the parties’ efforts to complete discovery have been affected by 14 Rosenberg’s unavailability for deposition and recent supplemental disclosures. Previously, Rosenberg 15 underwent a medical procedure in 2024 and experienced effects from the procedure which have delayed 16 Rosenberg’s responses to discovery requests and prevented him from attending his deposition despite 17 the fact said deposition was properly noticed during discovery. Now, Rosenberg is located out of the 18 country and unavailable for deposition until mid-October. 19 Here, the extension request is made in good faith as certain discovery deadlines could not be met 20 due to the actions described herein, the request is advanced jointly by the parties, and not for the 21 purposes of delay. Trial in this matter has not yet been set. Moreover, since this request is a joint 22 request, neither party will be prejudiced. 23 This request for an extension of deadlines is not sought for any improper purpose or other 24 purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient time to 25 conduct discovery and adequately prepare their respective cases for trial. 26 The parties respectfully submit that the reasons set forth above constitute compelling reasons for 27 the extension and that the failure to act was the product of excusable neglect. 1 IV. The proposed schedule for completing all remaining discovery. 2 Event Current Deadline Proposed Deadline 3 Amending and Adding September 2, 2024 N/A Parties 4 Initial Expert Disclosures July 2, 2025 N/A1 5 Rebuttal Expert Disclosures August 4, 2025 N/A 6 Close of Discovery September 3, 2025 December 5, 2025 7 Dispositive Motions October 2, 2025 January 5, 2026 8 Pretrial Order (including November 5, 2025 February 5, 2026 FRCP 26(a)(3) disclosures) 9 10 DATED this 13th day of October, 2025 DATED this 13th day of October, 2025 11 WILEY PETERSEN LAW OFFICES OF MONT E. TANNER 12 /s/ Jason M. Wiley /s/ Mont E. Tanner 13 _________________________________ ______________________________________ JASON M. WILEY, ESQ. MONT E. TANNER, ESQ. 14 Nevada Bar. No. 9274 Nevada Bar No. 4433 E.DANIEL KIDD, ESQ. 2950 East Flamingo Road 15 Nevada Bar No. 10106 Suite G 10000 W. Charleston Blvd., Suite 230 Las Vegas, Nevada 89121 16 Las Vegas, Nevada 89145 [email protected] Telephone: 702.910.3329 17 Facsimile: 702-553-3467 Attorney for Defendant Pavel Rosenberg [email protected] 18 [email protected] 19 Attorneys for Plaintiffs 20 21 [Order on following page] 22 1 The parties initially submitted a stipulation to extend discovery deadlines to the Court on 23 September 3, 2025, which was denied without prejudice. The Court’s Minute Order stated that the parties failed to explain their failure to move to extend discovery deadlines before the July and 24 August expert deadlines was the product of excusable neglect. The parties have subsequently 25 agreed that they do not need to disclose expert witnesses in this matter and, as such, are not seeking to extend the expert disclosure deadlines. This stipulation reflects the parties’ new position. 26 Upon receipt of the Court’s Minute Order, Plaintiff promptly revised the stipulation to 27 extend discovery and sent to Rosenberg’s counsel on September 10, 2025. Defendant’s counsel approved the stipulation on October 13, 2025. 1 IT IS SO ORDERED that the parties’ stipulation to extend discovery deadlines (ECF No. 55) is 2|| GRANTED. 3|| DATED: 10/14/2025

DANIEL J. ALBREGTS 6 UNITED STATES MAGISTRATE JUDGE 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28