Plaintiff’s Motion for Extension of Time to Respond to Counterclaim

Plaintiff and Counterclaim Defendant, Arthur Diskin (“Diskin”), by and through undersigned counsel, for good cause shown and before the expiration of the period prescribed for answering or otherwise pleading, and respectfully moves the Court pursuant to Rule 6(b) of the North Carolina Rules of Civil Procedure that he be allowed an extension of time of thirty (30) days within which to file a reply or otherwise respond to the Counterclaim of Defendant, Michael J. Shelley, and Defendant Spands Orbit, LLC (together, “Defendants”). In support of its motion, Diskin states that:

1. Defendants filed their Answer on May 26, 2026, and Diskin was served a copy of said Answer on May 27, 2026. This makes Diskin’s Reply due on June 26, 2026.
2. No prior extension has been sought, and the time for responding to the counterclaim has not yet expired.
3. Diskin is reasonably in need of additional time in which to consult with counsel, review relevant documentation, and then prepare appropriate answer or response to the complaint.
4. This motion is brought in good faith and not for purpose of delay.

Wherefore, Diskin respectfully requests that the Court grant it a thirty (30) day extension of time to reply or otherwise respond to Defendants’ counterclaim to and including Monday, July 27, 2026.

This the 4th day of June, 2026.