Plaintiff, Elaine Braxton, individually and as natural parent and guardian of D.N., a minor,

vs. Clark County School District; a Political Subdivision of the State of Nevada, Jesus F. Jara, in his individual and official capacity; Kody Barto, in his individual and official capacity; Gayle Orvedal, in her individual and official capacity; Michelle Brown, in her individual and official capacity; DOES I through X; and ROE CORPORATIONS I through X, inclusive,

IT IS HEREBY STIPULATED by and between the parties hereto, through their respective counsel of record, that the deadline for Plaintiff to file their Reply in Support to Plaintiff’s Motion to Amend Complaint (ECF 37) be extended until August 7, 2023.

Plaintiffs are requesting an extension to accommodate Plaintiffs’ counsel’s schedule, which does not provide a meaningful opportunity to prepare a response until August 7, 2023.

This request is being made in good faith and not for the purpose of delay.

List the case name and docket number of all appeals or original proceedings presently or previously pending before this court which are related to this appeal: None. 7.

List the case name, number and court of all pending and prior proceedings in other courts which are related to this appeal (e.g., bankruptcy, consolidated or bifurcated proceedings) and their dates of disposition: None.

If you are aware of any proceedings presently pending before this court which raises the same or similar issues raised in this appeal, list the case name and docket numbers and identify the same or similar issue raised: None known.

The Securities and Exchange Commission (the “Commission”) having filed a Complaint and Defendant America’s Rehab Campus, LLC (“ARC” or “Defendant”) having entered a general appearance; consented to the Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment:

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable on a joint and several basis with Defendants Michael B. Zipprich, Arizona Rehab Campus, LLC (“ARC-Op”), and America’s Rehab Campuses—Arizona, LLC (“ARC-AZ”) for disgorgement of $2,876,015.00, representing net profits gained as a result of the conduct alleged in the Complaint, together with prejudgment interest thereon in the amount of $507,401.36, and a civil penalty in the amount of $1,500,000.00 pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)].

expense an independent monitor (“Monitor”) not unacceptable to the staff of the Commission, to oversee the revenue, expenses, and distributions of Arizona Rehab Campus, LLC (“ARC-Op.”) to ensure compliance with the payment plan set forth in the Final Judgment; Immediately after installation of the Monitor, take such actions as are necessary to install a manager for ARC-Op not unacceptable to the staff of

Defendant shall submit the certification and supporting material to Ian S. Karpel, Assistant Regional Director, with a copy to the Office of Chief Counsel of the Enforcement Division, no later than sixty (60) days from the date of the completion of the undertakings.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment.

LLC is hereby appointed to serve without bond as trustee (the “Funds Trustee”) for all funds to be paid by Defendants pursuant to a judgment in this action, including post-judgment interest.

insured bank to receive and hold all funds to be paid by Defendants pursuant to a judgment in this action, including post-judgment interest (the “Funds”).

At least thirty (30) days prior to filing each Quarterly Fee Application with the Court, the Funds Trustee will serve upon counsel for the SEC a complete copy of the proposed Application, together with all exhibits and relevant billing information in a format to be provided by SEC staff.

All Quarterly Fee Applications will be interim and will be subject to cost benefit and final reviews at the close of the trusteeship.

Comply with the terms of the Billing Instructions agreed to by the Funds Trustee; and, Contain representations (in addition to the Certification required by the Billing Instructions) that: (i) the fees and expenses included therein were incurred in the best interests of the Investors; and, (ii) with the exception of the Billing Instructions, the Funds Trustee has not entered into any agreement, written or oral, express or implied, with any person or entity concerning the amount of compensation paid or to be paid from the Funds, or any sharing thereof.

The Securities and Exchange Commission (the “Commission”) having filed a Complaint and Defendant Arizona Rehab Campus, LLC (“ARC-Op” or “Defendant”) having entered a general appearance; consented to the Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment:

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 17(a)(3) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any means or instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly: to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 5(a) and (c) of the Securities Act [15 U.S.C. § 77e] by, directly or indirectly, in the absence of any applicable exemption:

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable on a joint and several basis with Defendants Michael B. Zipprich, America’s Rehab Campuses, LLC (“ARC”), and America’s Rehab Campuses—Arizona, LLC (“ARC-AZ”) for disgorgement of $2,876,015.00, representing net profits gained as a result of the conduct alleged in the Complaint, together with prejudgment interest thereon in the amount of $507,401.36, and a civil penalty in the amount of $1,500,000.00 pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)].

Defendant shall submit the certification and supporting material to Ian S. Karpel, Assistant Regional Director, with a copy to the Office of Chief Counsel of the Enforcement Division, no later than sixty (60) days from the date of the completion of the undertakings.

The Securities and Exchange Commission (the “Commission”) having filed a Complaint and Defendant America’s Rehab Campuses—Arizona, LLC (“ARC-AZ” or “Defendant”) having entered a general appearance; consented to the Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment:

to employ any device, scheme, or artifice to defraud; to make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or to engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.

to obtain money or property by means of any untrue statement of a material fact or any omission of a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 5(a) and (c) of the Securities Act [15 U.S.C. § 77e(a) and 77e(c)] by, directly or indirectly, in the absence of any applicable exemption:

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable on a joint and several basis with Defendants Michael B. Zipprich, America’s Rehab Campuses, LLC (“ARC”), and Arizona Rehab Campus, LLC (“ARC-Op”) for disgorgement of $2,876,015.00, representing net profits gained as a result of the conduct alleged in the Complaint, together with prejudgment interest thereon in the amount of $507,401.36, and a civil penalty in the amount of $1,500,000.00 pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)].

The Securities and Exchange Commission (“the Commission”) having filed a Complaint and Defendant Michael B. Zipprich, having entered a general appearance; consented to the Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction and except as otherwise provided herein in paragraph VII); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment:

to employ any device, scheme, or artifice to defraud; to make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or to engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.

to obtain money or property by means of any untrue statement of a material fact or any omission of a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 5(a) and (c) of the Securities Act [15 U.S.C. § 77e(a) and 77e(c)] by, directly or indirectly, in the absence of any applicable exemption:

Defendant shall submit the certification and supporting material to Ian S. Karpel, Assistant Regional Director, with a copy to the Office of Chief Counsel of the Enforcement Division, no later than sixty (60) days from the date of the completion of the undertakings.

None.

None.

None. 10.

The presumptively reasonable discovery period is 180 days.

Here, the parties seek a discovery period of 210 days.

Such generalized submissions do not constitute good cause for an extended discovery period.

The scheduling order in this case will be as follows: Initial Disclosures: Add/AmendPleadings: Initial Experts: Rebuttal Experts: June 29, 2023 July 25, 2023 August 24, 2023 September 25, 2023 Discovery Cut-Off October 23, 2023 Dispositive Motions: November22, 2023 Joint Pretrial Order: December 22, 2023, 30 daysafter the

Dated: June 20, 2023 resolution of dispositive motions, or further Court order.

By August 31, 2021, none of the cited conditions precedent had been met, including that not all governmental approvals had been obtained.

... PSA.34 The Sixth Cause of Action alleges that Peri has been "unjustly enriched" through the alleged wrongful tem1ination of the PSA.35 The Seventh Cause of Action-for Punitive Damages- isn't even a cause of action. but nonetheless ...

Case 2:23-cv-00603-JCM-NJK Document 11 Filed 06/14/23 Page 1of1 —" OoWONYDAWNffWWWN

Defendants.

al., To date, the parties have notfiled a stipulated discovery plan as required by Local Rule 26- 14]| 1(a).

The parties are hereby ORDEREDtofile, no later than June 21, 2023, a joint proposed 15]| discovery plan.

Dated: June 14, 2023 Gan fo United tesMagistrate Judge

IT IS HEREBY STIPULATED AND AGREED by and between the parties hereto, by and through their respective counsel of record, that the discovery deadlines in this case be extended by sixty (60) days as follows:

Defendants provided their Initial List Witness and Document Disclosure Pursuant to FRCP 26(a)(1) on April 6, 2023.

With the resulting delay of the Amended Complaints and time taken for Defendants to prepare an Answer, discovery has fast approached.

Based on the fact that neither Plaintiffs nor Defendants have served any discovery thus far, there is good cause to extend deadlines sixty (60) days.

As such, additional time is needed to propound written discovery and take depositions prior to the retention and disclosure of expert witnesses.

Nonetheless, DW states that if the Court believes it needs to review its billing statements to better determine whether disqualification is required, DW has no objection.

... 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Conflicts arising under Rule 1.9 may be imputed to the conflicted lawyer’s law firm under NRPC 1.10(a), which states: “While lawyers are associated in a firm, none ...

Per ECF No. 15, (Minutes of Proceedings of the Motion Hearing held on March 30, 2023), the above-entitled court dismissed multiple claims alleged in Plaintiffs’ Complaint, without prejudice, and with leave to amend.

Pursuant to that ruling, Plaintiff filed a First Amended Complaint on April 20, 2023 (ECF No. 24).

Thereafter, on April 28, 2023, the Parties received the transcript relating to the March 30, 2023, hearing (ECF No. 27).

Plaintiff Elaine Braxton, as natural parent, and guardian of D.N., wishes to file a second amended Complaint to better reflect the March 3, 2023, hearing, more accurately.

Based on the forgoing, the Parties have stipulated and agreed that Plaintiff may file a second amended complaint on or before May 10, 2023, and that Defendants responsive pleading will be due on or before May 31, 2023.

* * * Case No.: 2:23-cv-00144-JAD-BNW Stipulation and Order to Extend Deadline for Plaintiff to File Reply in Support to Plaintiffs ‘Motion to Permit Elaine Braxton to Obtain a Pre-settlement Loan (1st Request) ECF No. 25 Elaine Braxton, individually and as natural parent and guardian of D.N., a minor, Plaintiff, vs. Clark County School District; a Political Subdivision of the State of Jesus F. Jara, Nevada, in his individual and official capacity; Kody Barto, in his individual and official capacity; Gayle Orvedal, in her individual and official capacity; Michelle Brown, in her individual and official capacity; DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.

IT IS HEREBY STIPULATED by and between the parties hereto, through their respective counsel of record, that the deadline for Plaintiff to file their Reply in Support to Plaintiffs ‘Motion to Permit Elaine Braxton to Obtain a Pre-settlement Loan (ECF 16).

Plaintiffs’ Reply in Support is currently due today.

Plaintiffs are requesting a 3-day extension to accommodate Plaintiffs’ counsel’s schedule, which does not provide a meaningful opportunity to prepare a response until April 27, 2023.

This request is being made in good faith and not for the purpose of delay.