International Markets Live, Inc. v. IMONITIE et al, No. 2:2022cv01863 - Document 213 (D. Nev. 2023)

Court Description: ORDER Granting 212 Amended Stipulated Discovery Plan. Discovery due by 6/28/2024. Motions due by 7/29/2024. Proposed Joint Pretrial Order due by 8/27/2024. Signed by Magistrate Judge Brenda Weksler on 6/26/2023. (Copies have been distributed pursuant to the NEF - AMMi)

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International Markets Live, Inc. v. IMONITIE et al Doc. 213 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 1 of 11 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 1 P. Sterling Kerr, Esq. Nevada Bar No. 3978 2 George E. Robinson, Esq. Nevada Bar No. 9667 3 KERR SIMPSON ATTORNEYS AT LAW 2900 W. Horizon Ridge Parkway, Suite 200 4 Henderson, NV 89052 Phone: 702.451.2055 5 Fax: 702.451.2077 sterling@kerrsimpsonlaw.com 6 george@kerrsimpsonlaw.com 7 Lars K. Evensen, Esq. Nevada Bar No. 8061 8 Jenapher Lin, Esq. Nevada Bar No. 14233 9 HOLLAND & HART LLP 9555 Hillwood Drive, 2nd Floor 10 Las Vegas, NV 89134 Phone: 702.669.4600 11 Fax: 702.669.4650 lkevensen@hollandhart.com 12 jlin@hollandhart.com 13 Attorneys for Plaintiff/Counterdefendant International Markets Live, Inc. and 14 Counterdefendant Christopher Terry 15 16 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA INTERNATIONAL MARKETS LIVE INC., 17 a New York corporation dba IM MASTERY ACADEMY, 18 Plaintiff, 19 v. 20 DAVID IMONITIE an individual; SPELA 21 SLUGA, an individual; DEVON ROESER, an individual; IVAN TAPIA, an individual; 22 NVISIONU, INC., a Delaware corporation; ILYKIT, LLC, a Utah limited liability 23 company, LUCAS LONGMIRE, an individual; NATHAN SAMUEL, an 24 individual; MICHAEL ZHOR, an individual; IMRAN RICHIE, an individual; JUSTIN 25 OWENS, an individual; PAULO CAVALLERI, an individual; JOSE MIGUEL 26 CONTREAS, an individual; BASS GRANT, an individual; ANGELA CRUISHANK, an 27 individual; JEFF CRUISHANK, an individual; VINCE MURPHY, an individual; 28 GARY MCSWEEN, an individual; Case No.: 2:22-cv-01863-GMN-BNW FIRST AMENDMENT/CORRECTION TO FOURTH STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER SPECIAL SCHEDULING REVIEW REQUESTED 1 Dockets.Justia.com Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 2 of 11 1 KATRINA WORGESS, an individual; LUIS RONALDO HARNANDEZ ARRIAGA, an 2 individual; STEPHANIA AYO, an individual; SILVIA AYO, an individual; CATALINA 3 VASQUEZ, an individual; MATHIAS VASQUEZ, an individual; DOES 1 through 4 10, inclusive; and ROE CORPORATIONS I through X, inclusive, 5 Defendants. 6 AND ALL RELATED MATTERS. 7 AMENDMENT/CORRECTION: 8 The parties submit this first 9 amendment/correction to the 4th Stipulated DPSO (ECF Nos. 205, 209) to correct the 10 discovery cut off date (page 8, infra), which inadvertently stated “06/28/2023” instead of HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 “06/28/2024”. 12 Plaintiff INTERNATIONAL MARKETS LIVE INC., dba IM MASTERY ACADEMY 13 (“IML” or “Plaintiff”), and Defendants DAVID IMONITIE (“Imonitie”), SPELA SLUGA 14 (“Sluga”), DEVON ROESER (“Roeser”), IVAN TAPIA (“Tapia”), NVISIONU, INC. 15 (“NvisionU”), and ILYKIT, LLC, (“ILYKIT”) 1 (collectively, as the “Parties”), by and through their 16 respective undersigned counsel, having conducted their Supplemental Rule 26(f) conference on 17 December 5, 2022 and in accordance with Rules 16(b) and 26(f) of the Federal Rules of Civil 18 Procedure (“FRCP” or “Rule”) and Local Rule 26-1 (“LR”), submitted their Stipulated Discovery 19 Plan and Scheduling Order (“DPSO”), with special scheduling review requested (ECF No. 35), 20 which the Court approved on December 8, 2022 (ECF No. 37). 21 On February 14, 2023, the existing Parties and subsequently appearing Defendants BASS 22 GRANT, LUCAS LONGMIRE, and VINCE MURPHY, by and through their respective 23 undersigned counsel, conducted their supplemental Rule 26(f) conference and stated and proposed 24 no changes to the then existing DPSO (ECF Nos. 37, 120), which the Court approved on March 6, 25 2023 (ECF No. 126). 26 27 28 Plaintiff and ILYKIT have filed a Stipulation and Order of Dismissal of ILYKIT, LLC with prejudice (ECF No. 199), which is currently pending before the Court for approval. 1 2 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 3 of 11 1 On April 21, 2023, the parties to the Second DPSO (ECF No. 126) and subsequently 2 appearing Counterdefendant CHRISTOPHER TERRY, by and through their respective undersigned 3 counsel, conducted a supplemental Rule 26(f) conference regarding necessary 4 amendments/modifications to the discovery plan/scheduling order in light of Tapia’s Counterclaim 5 (ECF No. 44) and Imonitie’s Counterclaim (ECF No. 128) and, filed a proposed Third DPSO on 6 May 2, 2023 (ECF No. 158), stipulating and agreeing to certain changes to the Second DPSO (ECF 7 No. 126), which the Court approved on May 18, 2023 (ECF No. 177). 8 On June 19, 2023, the parties to the Third DPSO (ECF No. 177) and subsequently 9 appearing Defendants ANGELA CRUICKSHANK and JEFF CRUICKSHANK (collectively, as the 10 “Cruickshanks”) and JUSTIN OWENS (“Owens”), by and through their respective undersigned HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 counsel, conducted a supplemental Rule 26(f) conference regarding necessary 12 amendments/modifications to the discovery plan/scheduling order and, collectively, hereby 13 stipulate/agree to and propose the following certain changes to the Third DPSO (ECF No. 177) 14 (amendments/modifications in bold)2: 15 I. DISCOVERY PLAN 16 The following addresses each element of a Discovery Plan and Scheduling Order, a 17 summary of events and dates follows this narrative. 18 A. 19 Rule 26(a) Initial Disclosures. What changes should be made in the timing, form, or requirement for disclosures under Rule 26(a), including a statement of when initial disclosures were made or will be made. 20 The Parties agree that Initial Disclosures will be due on January 5, 2023, given the holidays. 21 The parties further agree that with respect to parties served or joined after the Rule 6(f) 22 conference, the time for initial disclosures will be governed by Rule 26(a)(1)(D), which provides 23 that “[a] party that is first served or otherwise joined after the Rule 26(f) conference must make the 24 initial disclosures within 30 days after being served or joined, unless a different time is set by 25 stipulation or court order.” 26 27 2 The Cruickshanks and Owens do not waive their pending challenge to personal jurisdiction by agreeing to extend discovery deadlines, participating in the supplemental Rule 26(f) conference, or stipulating to joining in the SPO. 28 3 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 4 of 11 1 B. 2 3 4 5 6 7 8 9 10 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 12 13 14 15 16 17 18 19 20 21 22 In this removed action, the first defendant otherwise appeared on November 4, 2022. (ECF No. 1). 3 The Parties agree that discovery as to claims and defenses is needed and that 270 days are required for discovery measured from December 5, 2022, the date of the Rule 26(f) Conference: Friday, September 1, 2023. The parties agreed a longer period of discovery – more than 180-days - is needed. The longer period is needed in light of the pending and anticipated motion practice, issues related to disputed expedited discovery, potential first amended complaint, potential Defendant(s) motion to assert counter-claim(s), as well as the number of defendants and the various states and some witnesses may reside in foreign countries. Upon supplementally conferring, the parties agree that an additional 180 days to the existing deadlines in the Second DPSO (ECF No. 126) is needed in light of the additional 19 claims and party counterdefendant newly added by Tapia’s Counterclaim (ECF No. 44) and Imonitie’s Counterclaim (ECF No. 128). Based on their supplemental Rule 26(f) conference and subsequent communications, the parties agree that an additional 120 days to the existing deadlines in the Third DPSO is needed (ECF No. 177) in light of these additional parties appearing in this action. The Cruickshanks and Owens have agreed to the 120 day extension in light of their pending motion to stay discovery. C. 23 24 25 26 27 Discovery Period; Scope/Extent of Discovery. The subjects on which discovery may be needed, when discovery should be completed, and whether discovery should be conducted in phases or be limited to or focused on particular issues. Amended Pleadings and Adding Parties As indicated above, Plaintiffs’ and Defendants each have indicated they may bring motion(s) to amended and add parties. There is no stipulation between the parties regarding Plaintiff’s prior motion to amend. The deadline to amend pleadings or add parties, 90-days before the close of discovery, is acceptable to all parties; Monday June 5, 2023. 3 Prior to removal, the first defendant answered in the State Court Action (A-22-854783-B) on 28 August 31, 2022. (ECF No. 5-5). 4 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 5 of 11 1 The parties agree to extend the current deadline to amend pleadings and add parties by 180 2 days from June 5, 2023 to November 30, 2023. 3 The parties agree to extend the current deadline to amend pleadings and add parties 4 by 120 days from November 30, 2023 to March 29, 2024. 5 D. 6 The parties are agreeable to setting the disclosure of experts 60-days before the close of Disclosure of Expert(s) Deadline 7 discovery, which is Monday, July 3, 2023 and rebuttal experts 30-days before the close of discovery, 8 which is Wednesday, August 2, 2023. 9 The parties agree to extend the current expert deadlines by 180 days: for initial expert 10 disclosures from June 7, 2023 to December 29, 2023; and for rebuttal expert disclosures from August HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 8, 2023 to January 29, 2024. 12 The parties agree to extend the current expert deadlines by 120 days: for initial expert 13 disclosures from December 29, 2023 to April 27, 2024; and for rebuttal expert disclosures from 14 January 29, 2024 to May 28, 2024. 15 E. 16 The parties are agreeable to setting dispositive motions 30-days after the close of discovery, Dispositive Motion Deadline 17 which is Monday, October 2, 2023. 18 The parties agree to extend the current dispositive motions deadline by 180 days from 19 October 2, 2023 to March 29, 2024. 20 The parties agree to extend the current dispositive motions deadline by 120 days from 21 March 29, 2024 to July 29, 2024. 22 F. 23 The parties are agreeable to the deadline for the join pre-trial order 30-days after the Joint Pre-Trial Order Deadline 24 dispositive-motion deadline, which is Wednesday November 1, 2023, and if dispositive motions are 25 filed, the deadline for fling the joint pretrial order will be suspended until 30-days after decision on 26 the dispositive motion or further order of the Court. 27 The parties agree to extend the current Joint Pretrial Order deadline by 180 days from 28 November 2, 2023 to April 29, 2024. 5 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 6 of 11 1 The parties agree to extend the current Joint Pretrial Order deadline by 120 days 2 from April 29, 2024 to August 27, 2024. 3 G. 4 Each Party does hereby certify that they have met and conferred during the December 5, Alternative Dispute Resolution 5 2022, Rule 26(f) conference and discussed the possibility of using the court’s alternative dispute 6 resolution process (“ADR”) including mediation, arbitration, and if applicable, early neutral 7 evaluation. Based on these discussions, the Parties mutually decline to participate in ADR at this 8 time, but will continue to evaluate alternative dispute resolution processes on a going forward basis. 9 10 H. Alternative Forms of Case Disposition. Each Party does hereby certify that they have met and conferred during the December 5, HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 2022, Rule 26(f) conference and discussed the possibility of using a magistrate judge under 28 12 U.S.C. § 636(c) and Fed. R. Civ. P. 73 and the use of the Short Trial Program (General Order 201313 01). The parties each declined this alternative. 14 I. 15 Electronically Stored Information (“ESI”). Any issues about disclosure, discovery, or preservation of electronically stored information, including the form or forms in which it should be produced. 16 IML filed a Motion to Establish ESI Protocol in Furtherance of Expedited Discovery, dated 17 November 18, 2022 (ECF No. 17), which the Magistrate Judge denied without prejudice and directed 18 the Parties to meet and confer (ECF No. 25). The Parties met and conferred regarding protocols 19 governing the production of ESI. IML circulated a draft Stipulation and Order Governing Production 20 of ESI. In response, Defendants proposed instead using the U.S. Northern District of California’s 21 model stipulated order re discovery of electronically stored information for standard litigation. IML 22 proposed redlines thereto. At the supplemental Rule 26(f) conference, the parties agreed that 23 Defendants will respond to Plaintiff’s proposed redlines by May 1, 2023 and if not in agreement 24 therewith shall participate in a supplemental meet and confer regarding the same on May 2, 2023, at 25 10:00 a.m. (PST). The Parties will determine if an ESI protocol can be agreed to, or if motion(s) 26 regarding the same will need to be filed to obtain guidance from the Court. 27 The Parties were unable to come to an agreeable ESI protocol. As a result, on May 28 8, 2023, Plaintiff filed its Motion to Establish ESI Protocol in Furtherance of Discovery. (ECF 6 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 7 of 11 1 No. 164). On May 22, 2023, Defendants filed their Joint Response (ECF No. 181), to which 2 Plaintiff replied on May 26, 2023 (ECF No. 185). The Motion to Establish ESI Protocol in 3 Furtherance of Discovery is currently pending before the Court for adjudication and is set to 4 be heard on July 18, 2023 at 1:00 p.m. 5 7 Privileges; Trial Preparation Materials. Any issues about claims of privilege or of protection as trial-preparation materials, including—if the parties agree on a procedure to assert these claims after production—whether to ask the court to include their agreement in an order under Federal Rule of Evidence 502. 8 Plaintiff and Defendants Imonitie, Sluga, Roeser, and Nvision have entered into a 6 J. 9 Protective Order Regarding Confidentiality (the “SPO”). (ECF No. 5-7). Defendants ILYKIT, 10 Tapia, Grant, Longmire, and Murphy have stipulated and joined in the SPO. (ECF Nos. 135, 136). HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 Defendants Angela Cruickshank, Jeff Cruickshank, and Justin Owens have stipulated and 12 agreed to join in the SPO. 13 K. 14 Limitations on Discovery. What changes should be made in the limitations on discovery imposed under these rules or by local rule, and what other limitations should be imposed. 15 There is currently a dispute concerning an order issued by the State District Court regarding 16 an order to show cause. Plaintiff believes the State Court Order is effective. Defendants David 17 Imonitie, Spela Sluga, Devon Roeser, and Nvisionu, Inc. have filed a motion seeking clarity 18 regarding the State Court Order, which is currently pending before this Court for adjudication. 19 Defendants also filed a motion to vacate order in the state court action, which was denied. (ECF No. 20 116). Depending on the ruling on this order, the Parties may revisit Limitation of Discovery. 21 On May 19, 2023, the Court entered its Order re ECF No. 161, granting in part and 22 denying in part Plaintiff’s Motion for Order Setting Number of Depositions Permitted Under 23 FRCP 30(a). (ECF No. 179). The Court’s Order grants Plaintiff’s Motion to the extent it seeks 24 to enlarge the number of depositions presumptively allowed with respect to depositions of the 25 named Defendants (ECF No. 179 at 4), but denied the remainder of Plaintiff’s Motion without 26 prejudice (ECF No. 179 at 2–3). 27 28 7 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 8 of 11 1 2 3 L. Other Orders. Any other orders that the court should issue under Rule 26(c) or under Rule 16(b) and (c). There are pending issues regarding the ESI Protocol and number of interrogatories that require resolution. 4 M. Electronic Evidence. 5 No jury trial demand has been made. 6 Tapia’s Counterclaim and Imonitie’s Counterclaim respectively demand “a jury for all 7 claims so triable.” Plaintiff/Mr. Terry anticipate they will likely present evidence in electronic format 8 to jurors. Defendants also anticipate using evidence in electronic format to the jurors. The parties 9 agree to meet and confer and attempt to reach a mutually agreeable stipulation governing the 10 presentation of electronic evidence, which shall be compatible and in accordance with the court’s HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 electronic jury evidence display system and any applicable rules/guidelines/instructions thereby. 12 II. SCHEDULING ORDER 13 FRCP 26(f); LR 26-1(b) Current Deadlines Proposed Deadlines 14 Discovery Cut-Off Date: Unless the court orders otherwise, discovery periods longer than 180 days from the date the first defendant answers or appears will require special scheduling review 02/28/2024 06/28/2024 Amending Pleadings & Adding Parties: Unless the discovery plan otherwise provides and the court so orders, the deadline for filing motions to amend the pleadings or to add parties is 90 days before the close of discovery FRCP 26(a)(2) Initial Expert Disclosures: Unless the discovery plan otherwise provides and the court so orders, the deadlines in Fed. R. Civ. P. 26(a)(2)(D) for expert disclosures are modified to require that the disclosures be made 60 days before the discovery cut-off date 11/30/2023 03/29/2024 12/29/2023 04/27/2024 FRCP 26(a)(2) Rebuttal Expert Disclosures: 01/29/2024 05/28/2024 15 16 17 18 19 20 21 22 23 24 25 26 27 28 8 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 9 of 11 1 2 3 4 5 6 7 8 9 10 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 12 13 14 15 16 17 18 19 20 21 22 Unless the discovery plan otherwise provides and the court so orders, the deadlines in Fed. R. Civ. P. 26(a)(2)(D) for expert disclosures are modified to require that rebuttal-expert disclosures be made 30 days after the initial disclosure of experts Interim Status Report: 60 days before the discovery cutoff as required by LR 26–3 12/29/2023 04/27/2024 Dispositive Motions: Unless the discovery plan otherwise provides and the court so orders, the deadline for filing dispositive motions is 30 days after the discovery cut-off date 03/29/2024 07/29/2024 Joint Pretrial Order: 04/29/2024 Unless the discovery plan otherwise provides and the court so orders, the deadline for the joint pretrial order is 30 days after the dispositive-motion deadline. If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order 08/27/2024 FRCP 26(a)(3) Disclosures. Unless the discovery plan otherwise provides and the court so orders, the disclosures required by Fed. R. Civ. P. 26(a)(3) and any objections to them must be included in the joint pretrial order; 08/27/2024 1) 04/29/2024 Later Appearing Parties. A copy of this DPSO will be served on any person 23 served after this DPSO is entered by the Court, or if an additional party appears, within five (5) days 24 of their first appearance. This DPSO will apply to later-appearing parties, unless the Court, on a 25 motion and for good cause shown, orders otherwise. 26 2) Modifications/Amendments to DPSO. This DPSO may only be modified for 27 good cause and with the Court’s consent. LR 26-4 governs modifications or extensions of any 28 deadlines set by this DPSO. All stipulations or motions to extend a deadline set forth in this DPSO 9 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 10 of 11 1 must be received by the Court no later than 21 days before the expiration of the subject deadline, 2 and must comply with LR 26-4. 3 4 HOLLAND & HART LLP SLIGHTING LAW 5 /s/ Lars K. Evensen Lars K. Evensen, Esq. Jenapher Lin, Esq. 9555 Hillwood Drive, 2nd Floor Las Vegas, NV 89134 /s/ Christopher Wellman Bradley S. Slighting, Esq. (NBN 10225) 1707 Village Center Cir., #100 Las Vegas, NV 89134 Telephone: (702) 232-2543 Email: brad@slightinglaw.com 6 7 8 9 10 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 DATED this 23rd day of June 2023. KERR SIMPSON ATTORNEYS AT LAW P. Sterling Kerr, Esq. George E. Robinson, Esq. 2900 W. Horizon Ridge Parkway, Suite 200 Henderson, NV 89052 11 Attorneys for Plaintiff/Counterdefendant International Markets Live, Inc. and 12 Counterdefendant Christopher Terry 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 THOMPSON BURTON, PLLC JON E. FIELD, ESQ. Nevada Bar No. 7700 One Franklin Park 6100 Tower Circle Suite 200 Franklin, Tennessee 37067 Tele: (615) 465-6000 Email: jfield@thompsonburton.com Attorney for Defendant ILYKIT, LLC Christopher Wellman (pro hac vice) California Bar No. 304700 WELLMAN & WARREN LLP 24411 Ridge Route, Suite 200 Laguna Hills, CA 92653 Tel: (949) 580-3737 cwellman@w-wlaw.com Attorneys for Defendants DAVID IMONITIE; SPELA SLUGA; DEVON ROESER; NVISIONU, INC., Bass Grant, Lucas Longmire, Vince Murphy SLIGHTING LAW /s/ Justin L. James Bradley S. Slighting, Esq. (NBN 10225) Justin L. James (pro hac vice) Utah Bar No. 15167 James Dodge Russell & Stephens PC 10 West Broadway, Suite 400 Salt Lake City, UT 84101 801.363.6363 jjames@jdrslaw.com Attorneys for Defendants Ivan Tapia, Justin Owens, Angela Cruickshank, Jeff Cruickshank IT IS SO ORDERED: UNITED STATES MAGISTRATE JUDGE 6/26/2023 DATED: _____________________________ 28 10 Case 2:22-cv-01863-GMN-BNW Document 213 Filed 06/26/23 Page 11 of 11 1 CERTIFICATE OF SERVICE I hereby certify that on the 23rd day of June 2023, a true and correct copy of the foregoing 2 3 FIRST AMENDMENT/CORRECTION TO FOURTH STIPULATED DISCOVERY PLAN 4 AND SCHEDULING ORDER (SPECIAL SCHEDULING REVIEW REQUESTED) was 5 served by the following method(s): 6 7 8 Electronic: by submitting electronically for filing and/or service with the United States District Court, District of Nevada’s e-filing system and served on counsel electronically in accordance with the E-service list to the following email addresses: Bradley S. Slighting (10225) SLIGHTING LAW 1707 Village Center Cir, Ste 100 Las Vegas, NV 89134 Tel: (702) 840-3749 brad@slightinglaw.com Bradley S. Slighting (10225) SLIGHTING LAW 1707 Village Center Cir, Ste 100 Las Vegas, NV 89134 Tel: (702) 840-3749 brad@slightinglaw.com Christopher Wellman (pro hac vice) California Bar No. 304700 WELLMAN & WARREN LLP 24411 Ridge Route, Suite 200 Laguna Hills, CA 92653 Tel: (949) 580-3737 cwellman@w-wlaw.com Justin L. James (pro hac vice) Utah Bar No. 15167 James Dodge Russell & Stephens PC 10 West Broadway, Suite 400 Salt Lake City, UT 84101 801.363.6363 jjames@jdrslaw.com Attorneys for Defendants David Imonitie; Spela Sluga; Devon Roeser; Nvisionu, Inc., Bass Grant, Lucas Longmire, Vince Murphy Attorneys for Defendants Ivan Tapia, Angela Cruickshank, Jeff Cruickshank, and Justin Owens 21 Jon E. Field, Esq. THOMPSON BURTON, PLLC One Franklin Park 6100 Tower Circle Suite 200 Franklin, Tennessee 37067 Tele: (615) 465-6000 Email: jfield@thompsonburton.com Nathan Samuel Pro Se litigant 1874 Brooks Dr NW Atlanta, GA 30318 Email: Nathanmorehouse171@gmail.com Tel: 516.282.5246 22 Attorney for Defendant ILYKIT, LLC 9 10 11 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 12 13 14 15 16 17 18 19 20 23 24 25 26 /s/ Brenda Schroeder An Employee of Holland & Hart LLP 27 28 11

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