Case 4:25-cv-01234      Document 60        Filed 04/24/26 in TXSD    Page 1 of 3


                        UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF TEXAS
                             HOUSTON DIVISION


 SUN ZHONGJIAN, individually and on
 behalf of all others similarly situated,

        Plaintiff,                               Case No. 4:25-cv-01234

 v.                                              Hon. Nicholas J. Ganjei

 ENCORE ENERGY CORP., PAUL
 GORANSON, and SHONA WILSON,

        Defendants.


            PLAINTIFF’S UNOPPOSED MOTION FOR CLARIFICATION

       Lead Plaintiff Øystein Kjelsvik (“Plaintiff”) respectfully submits this Motion for

Clarification in response to this Court’s Order dated April 22, 2026 (ECF No. 59),

regarding Plaintiff’s time to file a response in opposition to Defendants’ Motion to

Dismiss (ECF No. 55).

       The Court previously entered an Order ECF No. 14, later amended by ECF No. 23,

regarding certain parties which provided that Plaintiff “shall have sixty (60) days to oppose

Defendants’ motion to dismiss,” and “Defendants shall have forty-five (45) days thereafter

to file their reply in further support of the motion.” In accordance with ECF No. 14 and

ECF No. 23, Plaintiff’s time to file his opposition to Defendants’ Motion to Dismiss is May

11, 2026.


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     Case 4:25-cv-01234      Document 60       Filed 04/24/26 in TXSD   Page 2 of 3


       The Court’s April 22, 2026 Order appears to be in conflict with ECF No. 14 and

ECF No. 23. Plaintiff seeks clarification of which Order should govern when Plaintiff’s

Opposition is to be filed.

Dated: April 24, 2026                    Respectfully submitted,


                                         /s/ Joe Kendall
                                         Joe Kendall, Attorney-in-charge
                                         Texas Bar No. 11260700
                                         S.D. Tex. Bar. No. 30973
                                         KENDALL LAW GROUP, PLLC
                                         3811 Turtle Creek, Suite 825
                                         Dallas, Texas 75219
                                         (214) 744-3000
                                         jkendall@kendalllawgroup.com

                                         Texas Local/Liaison Counsel for Lead
                                         Plaintiff and the Proposed Class

                                         Jeffrey C. Block (pro hac vice)
                                         Jacob A. Walker (pro hac vice)
                                         Brendan Jarboe (pro hac vice)
                                         Sarah E. Delaney (pro hac vice)
                                         BLOCK & LEVITON LLP
                                         260 Franklin Street, Suite 1860
                                         Boston, MA 02110
                                         (617) 398-5600
                                         jeff@blockleviton.com
                                         jake@blockleviton.com
                                         brendan@blockleviton.com
                                         sarah@blockleviton.com

                                         Counsel for Lead Plaintiff and the Proposed
                                         Class


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     Case 4:25-cv-01234     Document 60         Filed 04/24/26 in TXSD    Page 3 of 3


                        CERTIFICATE OF WORD COUNT

      Per the Court’s Procedural Rules 16(b) and 16(c), I certify that this document has

been prepared in Times New Roman 13-point font, and, exclusive of those portions of the

document exempted, contains 151 words.

                                                        /s/ Joe Kendall
                                                        Joe Kendall


                         CERTIFICATE OF CONFERENCE

      Pursuant to the Court’s Procedural Rule 15(a), counsel for Lead Plaintiff conferred

with counsel for Defendants concerning this Motion. Defendants do not oppose this

Motion.

                                                        /s/ Joe Kendall
                                                        Joe Kendall


                            CERTIFICATE OF SERVICE

      I certify that all counsel of record have been served a true and correct copy of this

document by electronic submission for filing and service through the Electronic Case

Filing System of the Southern District of Texas on April 24, 2026.

                                                        /s/ Joe Kendall
                                                        Joe Kendall


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