2026 Membership Book FINAL

2:25-cv-575-APG-BNW MOTION HEARING - ROUGH DRAFT - DO NOT CITE!!!

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THE COURT: If I decide I need an evidentiary hearing on irreparable harm, how long -- think about this. You don't have to answer now. I'm going to throw this out to the other side, too, but how long would it take for you all to get ready for that? MR. HAVEMANN: I'll think about that, Your Honor, and I can represent that we would do it as quickly as possible. THE COURT: Okay. Let's turn to bond, as required by the rule. You say a de minimis bond, but I need to anticipate potential damages that could arise as a result of an improperly imposed restraining order. So what are the damages to the defendants if I improperly restrain it, in your mind, that would lead to a bond amount? MR. HAVEMANN: I'm not sure I can represent the defendant's harm. I mean -- THE COURT: I'm just guessing, if you've got any thoughts. Here's the thought that came to me: The State of Nevada contends it's here to protect the Nevada public from illegal improper sports betting. Accepting that as true for a second for purposes of the bond amount, the injury would be to all Nevadans who invested in these allegedly illegal sports contracts. So that would suggest the bond amount would be equal to whatever contracts, wagers, bets, whatever you want to call them, that Kalshi accepts from Nevada people. Why is that not an appropriate bond amount?

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UNITED STATES DISTRICT COURT Judy K. Moore, RMR, CRR

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