Crane Pomerantz, Esq. Nevada Bar No. 14103 2}| CLARK HILL PLC 1700 South Pavilion Center Drive, Suite 500 3|| Las Vegas, Nevada 89135 Telephone: (702) 697-7545 4|| Facsimile: (702) 862-8400 [email protected] 5 Logan D. Smith (Pro Hac Vice) 6|| [email protected] MCNAMARA SMITH LLP 7|| 655 West Broadway, Suite 900 San Diego, California 92101 Telephone: (619) 269-0400 Facsimile: (619) 269-0401 9|| Attorneys for Court-Appointed Receiver, Thomas W. McNamara 10 1l UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA FEDERAL TRADE COMMISSION and Case No. 2:25-cv-00760-CDS-NJK STATE OF NEVADA, 14 Plaintiffs Order Granting RECEIVER’S UNOPPOSED MOTION TO v. CONTINUE DATE FOR RECEIVER’S INTERIM REPORT AND HEARING INTERNATIONAL MARKETS LIVE, INC., et al., [ECF No. 197] 17 18 Defendants 19 Court-appointed receiver, Thomas W. McNamara (“Receiver”), respectfully submits this motion to request a brief continuance of the date to submit a status report to the Court regarding 21] the fulfillment of his duties under the Court’s recently-entered Preliminary Injunction. At the 22|| November 5 hearing, the Court ordered the Receiver to file a status report by December 2, 2025 and set a Status Hearing to take place on December 17, 2025. See ECF No. 192. The Receiver 24|| respectfully requests that consistent with this Court’s inherent authority to control the dockets of 25]| all cases before it as well as its “extremely broad” authority to manage equity receiverships (see, 26]| ¢.¢., SEC v. Hardy,

, 1037 (9th Cir. 1986)), good cause exists to grant an extension of one week (until December 9, 2025) for the Receiver to file his status report on account of 28]| intervening family commitments of the Receiver and his counsel during this coming

1 Thanksgiving week (November 22-29). The Receiver has consulted with counsel for the 2 Plaintiffs and counsel for the Defendants, and both sides did not object to the requested 3 extension. Since being appointed on a permanent basis, the Receiver has carried out numerous 4 tasks and will provide a full update for the Court in the forthcoming status report. To do so, the 5 Receiver respectfully seeks a one-week extension (until December 9, 2025) in light of work on 6 other cases as well as family commitments of the Receiver and counsel during the Thanksgiving 7 week. Specifically, the undersigned counsel will be out of the office traveling with family 8 during the week of Thanksgiving. 9 Granting this request is well within this Court‘s power, including its “extremely broad” 10 authority “to supervise an equity receivership and to determine the appropriate action to be taken 11 in [its] administration[.]” Hardy, 803 F.2d at 1037; see also SEC v. Amerindo Inv. Advisors 12 Inc.,

, at *2 (S.D.N.Y. May 20, 2016) (“a district court’s power to supervise 13 an equity receivership and to determine the appropriate action to be taken in the administration 14 of the receivership is extremely broad”) (citing Hardy, 803 F.2d at 1037-39); SEC v. Quiros, 966

(11th Cir. 2020) (“district court has broad powers and wide discretion to 16 determine relief in an equity receivership”); SEC v. Wealth Mgmt. LLC,

(7th 17 Cir. 2010) (in supervising an equitable receivership, district court has “broad equitable power”); 18 cf. SEC v. Hickey,

(9th Cir. 2003) (“The Supreme Court has repeatedly 19 emphasized the broad equitable powers of the federal courts to shape equitable remedies to the 20 necessities of particular cases, especially where a federal agent seeks enforcement in the public 21 interest.”). 22 Relatedly, the Court scheduled the next status hearing for December 17, which the Court 23 indicated was specifically set to occur two weeks after the filing of the Receiver’s status report in 24 order to allow for parties to make any objections to the Status Report. Should the Court grant the 25 extension to file the status report, the status hearing date must be addressed. Receiver’s counsel 26 discussed the options of maintaining the hearing on December 17, with any objections due by 27 December 16, or requesting a continuance to a date convenient for the Court on Wednesday 1|| of a status report on December 9 and holding a hearing on January 7 or after; Plaintiffs did not 2]| express a preference between those options. 3 For the foregoing reasons, the Receiver respectfully moves to continue the date to file his 4|| next status report from December 2, 2025 to December 9, 2025 and defers to the Court on the setting of the next status hearing. Dated: November 20, 2025 MCNAMARA SMITH LLP 7 By:___/s/ Logan D. Smith 8 Logan D. Smith (Pro Hac Vice) 655 West Broadway, Suite 900 9 San Diego, California 92101 [email protected] 10 Crane Pomerantz 11 Nevada Bar No. 14103 CLARK HILL PLC 12 1700 S. Pavilion Center Drive, Suite 500 Las Vegas, Nevada 89135 13 [email protected] 14 Attorneys for Court-Appointed Receiver, 1s Thomas W. McNamara

16 The Court having reviewed and considered the above Unopposed Motion to Continue Date for Receiver’s Interim Report and Hearing by the Receiver Thomas W. McNamara 18]| (“Receiver”), and good cause shown, 19 IT IS THEREFORE ORDERED that: 20 1) The Interim Report of the Receiver is due on December 9, 2025; and 21 2) The December 17, 2025 status hearing is vacated and continued to 22 January 7, 2026, at 10:00 a.m. in LV Courtroom 23 Dated: December 2, 2025 / 24 / 25 Cri . Silva 36 United States District Judge 27 28