STIPULATION TO EXTEND BRIEFING SCHEDULE

(FIRST REQUEST)

KENT J. DAWSON, District Judge.

This is the first stipulation to extend the briefing schedule for the Motion to Dismiss filed on June 10, 2019 and all related briefing.

WHEREAS; on March 25, 2019, plaintiff Dustin Gaj ("Plaintiff") filed his Verified Stockholder Derivative Complaint for Violation of Securities, Law, Breach of Fiduciary Duty, Waste of Corporate Assets, and Unjust Enrichment (the "Complaint") with the Court in the action, Gaj v. Wynn, Case No. 2:19-cv-00505-KJD-CWH (the "Action");

WHEREAS; on June 10, 2019, defendants Craig S. Billings, John J. Hagenbuch, Ray R. Irani, Jay L. Johnson, Matthew Maddox, Robert J. Miller, Patricia Mulroy, Clark T. Randt, Jr, Alvin V. Shoemaker, J. Edward Virtue, D. Boone Wayson, and nominal defendant Wynn Resorts, Ltd. filed a Motion to Dismiss or, in the Alternative, Stay Verified Stockholder Derivative Complaint for Violation of Securities, Law, Breach of Fiduciary Duty, Waste of Corporate Assets, and Unjust Enrichment (ECF No. 39) ("Director Defendants' Motion to Dismiss");

WHEREAS; on June 10, 2019 and June 11, 2019, defendant Stephen A. Wynn filed a notice of joinder and motion to dismiss complaint (ECF. Nos. 38, 46 and 47) (collectively with Director Defendants' Motion to Dismiss, the "Motions to Dismiss");

WHEREAS; defendant Stephen Cootey ("Cootey") has yet to respond to the Complaint and the parties agree that defendant Cootey may file a response to the Complaint on or before June 26, 2019;

WHEREAS; defendant Kimmarie Sinatra's ("Sinatra") counsel, Garman Turner Gordon, has accepted service and a Notice of a Lawsuit and Request to Waiver Service of a Summons was sent to defendant Sinatra's counsel on June 19, 2019; and

WHEREAS; the parties agree that defendant Sinatra may file a response to the Complaint on or before July 8, 2019; and

WHEREAS; a unified briefing schedule will serve judicial efficiency and conserve the resources of the Parties and the Court;

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties, through their respective counsel of record, as follows:

1. Plaintiff shall file an omnibus opposition to the pending Motions to Dismiss and any Motion to Dismiss filed by Cootey or Sinatra, with a maximum of forty-five (45) pages, on or before August 8, 2019; and

2. Defendants shall file their replies on or before September 2, 2019.

IT IS SO ORDERED.