i 8 f e 4 i é i i | f e 4 F H & g : 3 z 8 Electronically Filed 04/26/2012 12:01:49 PM > pas MPRI ORIGIN : Ross C. Goodman - Wien ann Nevada Bar No. 7722 GOODMAN LAW GROUP, P.C. ee eee ross@goodmanlawgroup.com 520 S. Fourth St., 2" Floor Las Vegas, Nevada 89101 Telephone: (702) 383-5088 Facsimile: (702) 385-5088 Attomeys for Plaintiff DISTRICT COURT CLARK COUNTY, NEVADA NICHOLAS DIAZ, Case No.: A-11-660642 Plaintiff, Dept. No.: XXXII y, MOTION FOR PRELIMINARY NEVADA STATE ATHLETIC INJUNCTION ON ORDER COMMISSION, SHORTENING TIME Defendant. COMES NOW Plaintiff Nicholas Diaz, by and through his attomey, ROSS C, GOODMAN, ESQ,, of the Goodman Law Group, and hereby requests this Honorable Court to grant his Motion for Preliminary Injunetion, This Motion is based upon the Points and Authorities and pleadings and papers on file herein, DATED this 2 day of April, 2012. GOODMAN LAW GROUP Attorneys for PlaintiffGOODMAN LAW GROUP (G02) 383-5088 \OTICE OF MOTION LAINTIFF’S MOTION FOR | PRELIMINARY INJUNCTION will come 2 on Feulasly for hearing on the day of You and each of you, will please take notice that 0 __m. or as soon thereafter as counsel may be » 2012, at the hour of“: a heard, in Department 32 in the above-referenced Court Dated this Wy of April, 2012. 520 SMourth Stfeet, Second Floor Las Vegas, NV 89101 Attorney for Plaintiff Nicholas Diaz ORDER SHORTENING TIME Upon the application of Defendant and good cause appearing therefore, IT IS HEREBY ORDERED that the time for hearing of the above-cntitled matter be, th and the same will be heard on the /Y “day of _ ay _, 2012, at the hour sened o of £2736 octock fhm in Desernent 3p This mopon shad be io Z by i : be led fie 2 Délenderrt by’ jay 1,2012.. ny appoositiin shat! DATED this ©¥ _ day of April, 2012. hes a Of2, rth i ye Pecy o LE? Ba JUDGE, DISTRICT COURT, DEPARTMENT 32. 520 South Fourth St Las Vegas, Nevada 89101 (702) 384-5563 Attorney for Plaintiff Nicholas DiazGOODMAN LAW GROUP “A Professional Corporation 5208. Fourth Street, 2! Floor oxon Las Vegas, Ne (702) 383-5088 DECLARATION OF COUNSEL IN SUPPORT OF ORDER SHORTENING TIME 1, ROSS C. GOODMAN, declare as follows 1, Thave personal knowledge of the facts set forth below, except for those factual statements expressly made upon information and belief, and as to those facts, I believe them to be true, and I am competent to testify. 2. Take this declaration in support of Nicholas Diaz’s Motion for Preliminary Injunction on Order Shortening Time. 3 Iam counsel of record for Nicholas Diaz (“Diaz”). 4, As established by the Affidavit of Nicholas Diaz, Diaz has been unable to Participate in any professional mixed martial arts contest, and therefore to carn a livelihood, since proceedings were commenced against him by the Nevada State Athletic Commission (the “NSAC”) on February 8, 2012 (the “Proceedings”). 5. Diaz's position is that the Proceedings are entirely without merit, and Diaz has sought a hearing for the final determination of the Proceedings on the earliest possible date. 6. However, nearly three months have passed since the Proceedings were commenced and a summary suspension of Diaz’s license to compete as a mixed martial artist ‘was effected by the NSAC (the “Summary Suspension”) . The NSAC has failed to sot a date for a final determination of the Proceedings, despite repeated requests. 7. Because of the NSAC’s delay in scheduling a prompt hearing for the final determination of the Proceedings, Diaz has already suffered irreparable injury, which injury is continuing. 8. Diaz stands to suffer further irreparable injury if Diaz’s motion for preliminary injunctive relief is not heard immediately.