STIPULATION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF, NIKKI GLOBAL, INC. TO RESPOND TO DEFENDANTS PHILIPPE ZIADE, JUDE NASSAR, APPLETON PROPERTIES, LLC, Z LEB GROUP, LLC, PROGRESSIVE CONSTRUCTION, INC., GROWTH DEVELOPMENT, LLC, VIBRANT REALTY, LLC, AJ PROPERTIES INTERNATIONAL, LLC, AJ PROPERTIES INTERNATIONAL SERIES 2, LLC, GROWTH HOLDINGS, LLC, GROWTH LUXURY HOMES, LLC, AND GROWTH LUXURY REALTY, LLC'S MOTION TO DISMISS

(First Request)

JAMES C. MAHAN, District Judge.

Plaintiff Nikkei Global Inc. ("Nikkei"), and Defendants Philippe Ziade, Jude Nassar, Appleton Properties, LLC, Z Leb Group, LLC, Progressive Construction, Inc., Growth Development, LLC, Vibrant Realty, LLC, AJ Properties International, LLC, AJ Properties International Series 2, LLC, Growth Holdings, LLC, Growth Luxury Homes, LLC, and Growth Luxury Realty, LLC (collectively, the "Ziade Defendants"), by and through their respective counsel, stipulate and agree as follows:

1. On October 18, 2018, Nikkei filed its Complaint [ECF No. 1] (the "Complaint");

2. On November 19, 2018, the Ziade Defendants accepted service of the Complaint.

3. On January 4, 2019, the Ziade Defendants filed their Motion to Dismiss [ECF No. 23] and served Nikkei with the same.

4. At the current time, Nikkei's Chief Executive Officer and President, Yukiko Minami ("Minami") is in Japan attending to her elderly mother who is experiencing a severe health crisis. Because Minami's participation is critical to Nikkei's ability to formulate its Opposition to the Ziade Defendants' Motion to Dismiss, Nikkei has requested that its deadline for filing of its Opposition be extended from January 18, 2019 through and including February 8, 2019.

5. Counsel for the Ziade Defendants have graciously agreed to this extension.

6. This is the first stipulation to extend the deadline to file a response to the Ziade Defendants' Motion to Dismiss. This stipulation is made in good faith and not to delay the proceedings.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

IT IS SO ORDERED.