3:21-cv-00495 | D. Nev. | Oct 11, 2022

Case 3:21-cv-00495-RCJ-CSD Document 54 Filed 10/11/22 Page 1 of 2

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UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 JUAN ULLOA, 8 CASE NO.: 3:21-cv-00495-RCJ-CSD Plaintiff, 9 ORDER TO EXTEND PLAINTIFF ’ S vs. TIME TO RESPOND TO 10 DEFENDANT ’ S MOTION TO DISMISS NEVADA GOLD MINES, a Delaware PLAINTIFF ’ S SECOND AMENDED 11 Limited Liability Company, COMPLAINT (ECF NO. 51) 12 Defendant. (FIRST REQUEST) 13 3 8 [9] [6] [0] [0] - Defendant, Nevada Gold Mines, LLC (“ Defendant ” or “NGM” ), by and through its [8] [1] [3] 14 5 2 [1]

P [1] 9 8 e M t ) i [2] u S A D [0] [7]

E counsel of record, ANTHONY HALL and JONATHAN MCGUIRE of SIMONS HALL ( , 15 A e K x v V a i

r F E & D N ♦ e 3 8 JOHNSTON, and Plaintiff Juan Ulloa, (“Plain tiff ” ) by and through his counsel of record, J.P. , r 16 P S

u A [1] z M [1] G A - [8] E . E 5 2 W

V KEMP of KEMP & KEMP, hereby stipulate and agree to extend the deadline for Plaintiff to file K 17 S ) [5] [2] 3 4 A

0 7 L [7] ( . l e his Response to NGM ’ s Motion to Dismiss Plaintiff ’ s Second Amended Complaint (ECF No. 18 T

51). The response, currently due on September 22, 2022, will be extended by two (2) weeks to and including October 6, 2022.

The reason for the extension, as Plaintiff ’ s counsel has informed Defense Counsel is that Plaintiff ’ s counsel was on vacation out of the country when the motion was filed on September 8, 2022 and did not return to the office until September 19, 2022. Therefore, he has not had time to address the 21-page motion by the current deadline. /// /// ///

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Case 3:21-cv-00495-RCJ-CSD Document 54 Filed 10/11/22 Page 2 of 2

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This is the parties first request for an extension of time for Plaintiff to respond to

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Defendant

’ s motion (ECF No. 51) and is made in good faith and not for the purpose of delay.

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DATED: September 22, 2022

DATED: September 22, 2022 5 October 11, 2022

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KEMP & KEMP

SIMONS HALL JOHNSTON PC

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/s/ James P. Kemp, Esq.

_ /s/ Jonathan A. McGuire, Esq._

James P. Kemp, Esq.

Anthony L. Hall, Esq.

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Jonathan A. McGuire, Esq. KEMP & KEMP

SIMONS HALL JOHNSTON PC

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7435 W. Azure Drive

690 Sierra Rose Drive

Suite 110

Reno, Nevada 89511

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Las Vegas, Nevada 89130

AHall@SHJNevada.com

JP@Kemp-attorneys.com

JMcGuire@SHJNevada.com

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Attorneys for Plaintiff Attorneys for Defendant

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[9] [6] [0] [0] - [8] [1] [3] 14 5 2 [1] P [1] 9 8 e M t ) i [2] u S A D [0] [7]

E ecf@parsonsb ( , 15 A e K x v V a i r F E ORDER & D N ♦

e 3 8 , r 16 P S u A [1] z M [1] G A IT IS SO ORDERED. - [8] E . E 5 2 W

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K 17 S ) [5] [2] 3 4 A

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[7] ( . l e 18 T Dated:

_____________________________________________

UNITED STATES DISTRICT JUDGE

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