Meagher v. Telus International (U.S.) Corp

1} ANTHONY L. MARTIN Nevada Bar No. 8177 [email protected] DANA B. SALMONSON Nevada Bar No. 11180 4| [email protected] OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.

5 | Wells Fargo Tower Suite 1500 ©! 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 | Fax: 702.369.6888 9| Attorneys for Defendant TELUS International (U.S.) Corp. 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA | BRIELLE MEAGHER, individually, and on Case No.: 2:20-cv-02074-RFB-DJA i, behalf of all others similarly situated, 15 Plaintiff, STIPULATION AND ORDER FOR AN $y EXTENSION TO STAY ALL 16 Vs. PROCEEDINGS PENDING SETTLEMENT é TELUS INTERNATIONAL (U.S.) CORP., DISCUSSIONS 20 Pursuant to LR IA 6-1, LR IA 6-2 and LR 7-1, Plaintiff Brielle Meagher (‘Plaintiff’) and Defendant TELUS International (U.S.) Corp (“Defendant”), by and through their respective | counsel of record, hereby stipulate and agree to stay all proceedings in this action for seventy-eight | (78) days up to and including June 15, 2021 to allow the parties to attend mediation in this matter.

94 | The parties have scheduled mediation for June 8, 2021. This is the parties’ second request for an extension of time. The first request for an extension of time was filed on January 26, 2021 (ECF | No. 21) and granted on February 11, 2021 (ECF No. 23).

27 The purpose of the Stay is to promote judicial economy and allow this court to more | effectively control the disposition of the cases on its docket with economy of time and effort for } itself, for counsel, and the litigants. See Landis v. N. Am. Co., 299 U.S. 248, 254 (U.S. 1936) (“the power to stay proceedings is incidental to the power inherent in every court to control the | disposition of the causes on its docket with economy of time and effort for itself, for counsel, and 4] for litigants”); Pate v. DePay Orthopedics, Inc. 2012 WL 3532780, at * 2 (D. Nev. Aug. 14, 2012) 5] (A trial court may, with propriety, find it is efficient for its own docket and the fairest course for 6] the parties to enter a stay of an action before it, pending resolution of independent proceedings || which bear upon the case”), citing Leyva v. Certified Grocers of Cal., Ltd. 593 F.2d 857, 863 (9th | Cir. 1979).

9 Pending the outcome of the parties’ mediation, the parties will provide a Status Report to | the Court no later than June 15, 2021 setting forth the following dates: 11 1) Should the parties resolve this matter at mediation, the parties will set forth a | briefing schedule for joint settlement approval.

13 2) Should the parties be unsuccessful, Defendant will have up to and including July 6, : 14] 2021 to file its response to Plaintiff's Class Action Complaint.

15 Should the parties need additional time in excess of the stay for reasons related to 16] rescheduling of the mediator, they reserve the right to request additional time from the Court.

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1 This Stipulation is made in good faith and is not intended for purposes of delay.

2 | DATED this 24th day of March, 2021. DATED this 24th day of March, 2021.

3 || BRown, LLC OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.

5 /s/ Nicholas R. Conlon /s/ Dana B. Salmonson Nicholas R. Conlon (admitted pro hac vice) | Anthony L. Martin | Jason T. Brown (admitted pro hac vice) Nevada Bar No. 8177 Town Square Place, Suite 400 Dana B. Salmonson 7} Jersey City, NJ 07310 Nevada Bar No. 11180 8 Wells Fargo Tower Don Springmeyer Suite 1500 g | Nevada Bar No. 1021 3800 Howard Hughes Parkway KEMP JONES, LLP Las Vegas, NV 89169 | 3800 Howard Hughes Parkway Attorneys for Defendant Wells Fargo Tower, 17th Floor Las Vegas, NV 89169 | Attorneys for Plaintiff te ORDER 15 IT IS SO ORDERED. a B17 RICHA LWARE, 9 United States District Court DATED this 24th day of March, 2021.