STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT FOR DEFENDANT BRENNAN SWAIN

ROBERT C. JONES, Chief District Judge.

This Stipulation to Extend Time to Return Waiver of Service of Summons and Respond to Complaint for Defendant Brennan Swain ("Stipulation") is entered into by and among Robb Evans of Robb Evans & Associates LLC ("Plaintiff"), the Receiver over I Works, Inc. and over 60 other named Defendant Entities, as well as unnamed subsidiaries and affiliates thereof, and over the assets of Jeremy Johnson, by and through his counsel, and defendant Brennan Swain ("Defendant"), with reference to the following facts:

RECITALS

A. The Plaintiff was appointed Temporary Receiver pursuant to a Temporary Restraining Order issued on January 13, 2011 in the civil enforcement action entitled Federal Trade Commission v. Jeremy Johnson, etc., et al., Case No. 2:10-cv-02203-MMD-GWF pending in the United States District Court for the District of Nevada. The Plaintiff became Permanent Receiver pursuant to a Preliminary Injunction Order issued on February 10, 2011.

B. On October 30, 2012, Plaintiff filed the Complaint in the above-captioned action.

C. On January 11, 2013, Plaintiff mailed a Notice of Lawsuit and Request for Waiver of Service of Summons to Defendant.

D. Defendant signed and returned the Waiver of Service of Summons.

E. Under Federal Rules of Civil Procedure Rule 4(d), Defendant was required to file a response to the Complaint no later than March 12, 2013.

F. Defendant has requested additional time to respond to the Complaint.

G. This Stipulation represents Defendant's first request for an extension of time to respond to the Complaint.

NOW, THEREFORE, in consideration of the foregoing, the parties hereto do stipulate and agree as follows:

1. The deadline for the Defendant to respond to the Complaint shall be extended to and including March 18, 2013.

WHEREFORE, the parties pray this Honorable Court endorse this Stipulation as outlined herein and set forth below.

ORDER

IT IS SO ORDERED.