1 || Ruben Limonjyan, Esq. (SBN 305307) rlimonjyan @lawgroupla.com 2 Arakelyan, Esq. (SBN 297677) zarakelyan @lawgroupla.com 3 || Robert Meehan, Esq. (SBN 356701) 4 tmeehan @lawgroupla.com LIMONJYAN LAW GROUP, APC 5 N. Central Ave, Suite 2210 Glendale, CA 91203 6 || Tel: (213) 277-7444 5 Fax: (213) 866-9636 g || Attorneys for Plaintiff, ROSARIO SOTO 9 Anthony J. Decristoforo (SBN 166171) 10 || anthony.decristoforo @ ogletree.com Spencer S. Turpen (SBN 296483) spencer turpen @oglctree.com D GLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 13 Capitol Mall, Suite 2800 Sacramento, CA 95814 14 Telephone: 916-840-3150 Facsimile: 916-840-3159

16 Attorneys for Defendant ARTHUR J. GALLAGHER SERVICE COMPANY 17 18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA 20 21 |} ROSARIO SOTO, an individual, ) Case No. 2:24-CV-03055-WBS-CSK Plaintiff. 33 aintitt, ) JOINT STIPULATION TO REQUEST v. ) MODIFICATION TO STATUS 24 (PRETRIAL SCHEDULING) ORDER 2 ° ARTHUR J. GALLAGHER SERVICE || COMPANY, a Delaware Corporation, and ) Complaint Filed: September 17, 2024 97 || DOES 1 through 20, Inclusive, Trial: June 9, 2026

Defendants. ) -|-

1 Pursuant to the Court’s Status (Pretrial Scheduling) Order, Plaintiff ROSARIO 2 || SOTO (‘Plaintiff’) and Defendant ARTHUR J. GALLAGHER SERVICE COMPANY 3 || (“Defendant”) (collectively “Parties”), by and through their respective counsel, hereby 4 || agree and stipulate, and make the following request to modify the Court’s existing order 5 follows: 6 WHEREAS, April 1, 2025, the Court issued the Status (Pretrial Scheduling) 7 Order, which provided, in relevant part, that: 8 1. All discovery, including depositions for preservation of testimony, shall be 9 completed by December 1, 2025, and all motions to compel discovery must be 10 noticed and heard by that date; 11 2. Motion filing deadline: January 26, 2026; 12 3. Final Pretrial Conference: April 6, 2026; 13 4. Trial: June 9, 2026; 14 WHEREAS, on October 7, 2025, the Court granted the Parties’ stipulation 15 || extending the expert disclosure deadlines as follows: 16 1. The Parties shall disclose experts and produce reports in accordance with 17 Federal Rule of Civil Procedure 26(a)(2) by no later than January 6, 2026; 18 2. Expert testimony intended solely for rebuttal shall be disclosed and reports 19 produced in accordance with Federal Rule of Civil Procedure 26(a)(2) on or 20 before February 5, 2026; and 21 3. The Parties shall complete depositions of experts on or before March 6, 2026; 22 WHEREAS, the Parties have diligently participated in discovery, including 23 ||exchanging written discovery, producing documents, and conducting the first day of 24 || Plaintiff's deposition; 25 WHEREAS, the second day of Plaintiff's deposition was noticed and confirmed 26 || by the Parties for November 3, 2025, and the depositions of several of Defendant’s 27 ||/current and former employees have been noticed for dates in November 2025; 28 WHEREAS, on November 2, 2025, counsel for the Parties learned that Plaintiff

1 sustained an unexpected health-related problem that prevented her from sitting for 2 ||her deposition on November 3, 2025, causing her deposition to be postponed; 3 WHEREAS, the Parties anticipate that Plaintiff's deposition will be rescheduled 4 || and completed by December 15; 5 WHEREAS, the Parties agree that depositions should proceed in the same 6 sequence as currently noticed, with Plaintiff's deposition to be completed prior to the 7 || depositions of Defendant’s witnesses; 8 WHEREAS, under Federal Rule of Civil Procedure 16(b)(4), a pre-trial schedule 9 ||“may be modified only for good cause and with the judge’s consent.” Good cause 10 || requires a showing of diligence. Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992); 12 WHEREAS, the Parties have met and conferred and agree that good cause exists 13 under Federal Rule of Civil Procedure 16(b)(4) to extend the deadline to complete the 14 || currently-noticed depositions and other remaining deadlines in the Scheduling Order ; 15 WHEREAS, this request is made in good faith, not for purposes of delay, and will 16 prejudice any Party; 17 WHEREAS, the Parties have met and conferred, and agreed and hereby stipulate 18 || to request the following modification to the Court’s Status (Pretrial Scheduling) Order: 19 1. All currently noticed depositions, including depositions for preservation of 20 || testimony, shall be conducted so as to be completed by January 30, 2026. All motions to 21 ||compel discovery relating to currently noticed depositions shall be noticed and heard by 22 ||that date. The Parties do not intend to extend the deadline to complete discovery other 23 ||than currently noticed depositions. 24 2. The Parties shall disclose experts and produce reports in accordance with 25 || Federal Rule of Civil Procedure 26(a)(2) by no later than March 6, 2026; 26 3. Expert testimony intended solely for rebuttal shall be disclosed and reports 27 || produced in accordance with Federal Rule of Civil Procedure 26(a)(2) on or before April 6, 2026; .

1 4. The Parties shall complete depositions of experts on or before May 6, 2026; 2 5. All dispositive motions shall be filed on or before February 27, 2026; 3 6. The Final Pretrial Conference shall be continued to June 15, 2026, at 1:30 4 || p.m., or the next date convenient for the Court; 5 7. The Jury Trial to be continued until August 11, 2026. 6 7 IT IS SO STIPULATED. 8 9 || Dated: November 5, 2025 LIMONJYAN LAW GROUP, APC 10 11 D By: _ /s/ Robert Meehan Ruben Limonjyan, Esq. 13 Zara Arakelyan, Esq. 14 Robert Meehan, Esq. Attorneys for Plaintiff, I5 ROSARIO SOTO 16 17 18 || Dated: November 5, 2025 OGLETREE, DEAKINS, NASH, 19 SMOAK & STEWART, P.C. 20 21 22 By: __/s/ Anthony J. DeCristoforo 53 Anthony J. DeCristoforo, Esq. Spencer S. Turpen, Esq. 24 Attorneys for Defendant, 25 ARTHUR J. GALLAGHER SERVICE COMPANY

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1 ORDER 2 3 THIS COURT, having read and considered the Joint Stipulation to Request 4 || Modification to the Status (pretrial Scheduling) Order by, between and among Plaintiff 5 || ROSARIO SOTO (“Plaintiff”) and Defendant ARTHUR J. GALLAGHER SERVICE 6 || COMPANY (“Defendant”) (collectively “Parties”), and finding good cause therefor, 7 || orders as follows: 8 1. All currently noticed depositions, including depositions for preservation of 9 testimony, shall be conducted so as to be completed by January 30, 2026. 10 All motions to compel discovery related to currently noticed depositions 11 shall be noticed and heard by that date. This Order does not extend the 12 deadline to complete discovery other than currently noticed depositions. 13 2. The Parties shall disclose experts and produce reports in accordance with 14 Federal Rule of Civil Procedure 26(a)(2) by no later than March 6, 2026; 15 3. Expert testimony intended solely for rebuttal shall be disclosed and reports 16 produced in accordance with Federal Rule of Civil Procedure 26(a)(2) on or 17 before April 6, 2026; 18 4. The Parties shall complete depositions of experts on or before May 6, 2026; 19 5. All dispositive motions shall be filed on or before February 27, 2026; 20 6. The Final Pretrial Conference shall be continued to June 15, 2026, 1:30 21 p.m.; 22 7. The Jury Trial to be continued until August 11, 2026, at 9:00 a.m. 23 24 IS SO ORDERED. 25 ||Dated: November 6, 2025 dh ble a. (et. 26 WILLIAM B. SHUBB UNITED STATES DISTRICT JUDGE

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