Iraci v. Bradford — Entry #23: ORDER Granting 21 Stipulation to Extend Deadline to Answer 1 Petition for Removal
Case: Iraci v. Bradford nvd · 2:23-cv-00315
filed February 28, 2023
What this document is
Docket entry #23 · filed April 05, 2023
ORDER Granting 21 Stipulation to Extend Deadline to Answer 1 Petition for Removal. Roger P. Beynon answer due 4/24/2023; Zachary K. Bradford answer due 4/24/2023; CleanSpark, Inc. answer due 4/24/2023; Lori L. Love answer due 4/24/2023; Larry McNeill answer due 4/24/2023; S. Matthew Schultz answer due 4/24/2023; Thomas L. Wood answer due 4/24/2023. Signed by Judge Jennifer A. Dorsey on 4/5/2023. (Copies have been distributed pursuant to the NEF - KF)
Who is involved
- Bradford
- Iraci
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- CleanSpark: its name “CleanSpark, Inc.” appears in a filing in this case.
…Thomas L. Wood and Nominal Defendant Cleanspark, Inc. 7 8 UNITED…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 27, 2026. Federal court filings are public records.
Document text
3 page(s), 6,150 characters, converted from the PDF's text layer · plain text.
Full text
Case 2:23-cv-00315-JAD-NJK Document 23 Filed 04/05/23 Page 1 of 3
1 MARK J. CONNOT (10010)
COLLEEN E. MCCARTY (13186)
2 FOX ROTHSCHILD LLP
1980 Festival Plaza Drive, Ste. 700
3 Las Vegas, NV 89135
Telephone: 702.262.6899
4 Facsimile: 702.597.5503
mconnot@foxrothschild.com
5 cmccarty@foxrothschild.com
Counsel for Defendants Zachary K. Bradford, Lori L. Love,
6 S. Matthew Schultz, Robert P. Beynon, Larry McNeill, and
Thomas L. Wood and Nominal Defendant Cleanspark, Inc.
7
8 UNITED STATES DISTRICT COURT
9 DISTRICT OF NEVADA
10
NICHOLAS IRACI, Derivatively on Behalf of Case No.: 2:23-cv-00315-JAD-NJK
11 CLEANSPARK, INC.,
Plaintiff, (Removal from District Court, Clark County,
12 Nevada, Case No. A-23-866172-C)
v.
13
14 ZACHARY K. BRADFORD, LORI L. LOVE,
S. MATTHEW SCHULTZ, ROGER P. JOINT STIPULATION AND ORDER
15 BEYNON, LARRY MCNEILL, and THOMAS EXTENDING TIME TO RESPOND TO
L. WOOD, COMPLAINT
16
Defendants,
17
ECF No. 21
18 -and-
19 CLEANSPARK, INC., a Nevada Corporation,
20 Nominal Defendant.
21
22 Plaintiff Nicholas Iraci (“Plaintiff”), derivatively on behalf of Nominal Plaintiff
23 CleanSpark, Inc. (“CleanSpark”) and Defendants Zachary K. Bradford, Lori L. Love, S.
24 Matthew Schultz, Larry McNeill, Thomas L. Wood, Roger P. Beynon (the “Individual
25 Defendants”), and Nominal Defendant CleanSpark (together with the Individual Defendants,
26 “Defendants”) (collectively, with Plaintiff, the “Parties”), by and through their undersigned
27 counsel, hereby enter into the following stipulation and proposed order:
28 ///
1
144371336.1
Case 2:23-cv-00315-JAD-NJK Document 23 Filed 04/05/23 Page 2 of 3
1 WHEREAS, on February 24, 2023, Plaintiff filed a shareholder derivative complaint (the
2 “Complaint”) on behalf of Nominal Plaintiff CleanSpark in the Eighth Judicial District Court of
3 the State of Nevada in and for Clark County (the “State Court”), captioned Iraci v. Bradford, et
4 al., Case No. A-23-866172-C (this “Action”); and
5 WHEREAS, on February 28, 2023, the Defendant S. Matthew Schultz filed a Petition
6 for Removal (Dkt. 1) and Notice of Removal, removing this Action from State Court to the
7 United States District Court for the District of Nevada; and
8 WHEREAS, on March 24, 2023, the Individual Defendants filed a Motion to
9 Consolidate, asking the Court to consolidate this Action into the consolidated shareholder
10 derivative action pending in the United States District Court for the District of Nevada, In re
11 CleanSpark, Inc. Derivative Litigation, Case No. 2:21-cv-01181-GMN-BNW (the “Motion to
12 Consolidate”) (Dkt. 15); and
13 WHEREAS, on March 30, 2023, Plaintiff filed the Motion to Remand and for Attorney’s
14 Fees and Costs, which has been noticed for consideration by the Court in the normal course (the
15 “Motion to Remand”) (Dkt. 16); and
16 WHEREAS, Defendants intend to move to dismiss the Complaint in this Action; and
17 WHEREAS, the Parties agree to extend the deadline for Defendants to respond to the
18 Complaint until on or before April 24, 2023.
19 WHEREAS, the Parties agree to extend the deadline for Plaintiff to oppose any motion
20 to dismiss the Complaint that Defendants file until on or before May 24, 2023.
21 WHEREAS, the Parties agree to extend the deadline for Defendants to reply in support
22 of any motion to dismiss the Complaint until on or before June 14, 2023.
23 NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by the Parties
24 hereto, through their undersigned counsel, subject to the approval of the Court, as follows:
25 1. Defendants’ deadline to respond to the Complaint is extended until on or before
26 April 24, 2023.
27 2. Plaintiff’s deadline to oppose any motion to dismiss the Complaint that
28 Defendants file is extended until on or before May 24, 2023.
2
144371336.1
Case 2:23-cv-00315-JAD-NJK Document 23 Filed 04/05/23 Page 3 of 3
1 3. Defendants’ deadline to reply in support of any motion to dismiss the Complaint
2 that Defendants file is extended until on or before June 14, 2023.
3 4. Other than as agreed herein, the Parties reserve all rights.
4
5 DATED: April 4, 2023 DATED: April 4, 2023
6
FOX ROTHSCHILD LLP ALDRICH LAW FIRM, LTD.
7
/s/ Colleen E. McCarty /s/ John P. Aldrich
8 MARK J. CONNOT (10010) JOHN P. ALDRICH (6877)
COLLEEN E. MCCARTY (13186) CATHERINE HERNANDEZ (8410)
9 1980 Festival Plaza Drive, Ste. 700 7866 West Sahara Avenue
10 Las Vegas, NV 89135 Las Vegas, Nevada 89117
mconnot@foxrothschild.com jaldrich@johnaldrichlawfirm.com
11 cmcarty@foxrothschild.com chernandez@johnaldrichlawfirm.com
Counsel for Defendants Counsel for Plaintiffs
12
13
14
IT IS SO ORDERED.
15
16 _____________________________________
UNITED STATES DISTRICT JUDGE
17 DATED: April 5, 2023
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