ANTHONY L. MARTIN Nevada Bar No. 8177 2 [email protected] 3 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 7 Las Vegas, NV 89169 Telephone: 702.369.6800 8 | Fax: 702.369.6888 Attorneys for Defendant TELUS International (U.S.) Corp. 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 g BRIELLE MEAGHER, individually, and on Case No.: 2:20-cv-02074-RFB-DJA 13 _ behalf of all others similarly situated, 15 Plaintitt, STIPULATION AND ORDER TO EXTEND 3 vs CURRENT STAY PENDING MEDIATION 16 * 47] TELUS INTERNATIONAL (U.S.) CORP., (THIRD REQUEST) a 18 Defendant. 19 20 Pursuant to LR JA 6-1, LR IA 6-2 and LR 7-1, Plaintiff Brielle Meagher (“Plaintiff”) and 21 Defendant TELUS International (U.S.) Corp (“Defendant”), by and through their respective 22 counsel of record, hereby stipulate and agree to continue the current stay in this action to allow the 23 54 parties to attend mediation in this matter. The current stay ends June 15, 2021. (ECF No. 27.) 35 The parties had scheduled mediation for June 8, 2021 but, due to unforeseen circumstances, the

mediation has been continued to July 1, 2021. Accordingly, the parties are requesting to continue

57 the current stay to July 12, 2021. This is the parties’ third request for an extension of time. The

38 first request for an extension of time was filed on January 26, 2021 (ECF No. 21) and granted on

1} February 11, 2021 (ECF No. 23). The second request for an extension of time was filed on March 2} 24, 2021 (ECF No. 26) and granted on March 25, 2021 (ECF No. 27). 3 The purpose of the Stay is to promote judicial economy and allow this court to more 4] effectively control the disposition of the cases on its docket with economy of time and effort for 5 | itself, for counsel, and the litigants. See Landis v. N. Am. Co.,

(U.S. 1936) (“the 6] power to stay proceedings is incidental to the power inherent in every court to control the 7] disposition of the causes on its docket with economy of time and effort for itself, for counsel, and 8 | for litigants”); Pate v. DePay Orthopedics, Inc.

, at * 2 (D. Nev. Aug. 14, 2012) 9} (“A trial court may, with propriety, find it is efficient for its own docket and the fairest course for 10] the parties to enter a stay of an action before it, pending resolution of independent proceedings 11 | which bear upon the case”), citing Leyva v. Certified Grocers of Cal., Ltd.

(9th 12] Cir. 1979). 13 Pending the outcome of the parties’ mediation, the parties will provide a Status Report to : 14] the Court no later than July 12, 2021 setting forth the following dates: 15 1) Should the parties resolve this matter at mediation, the parties will set forth a 16] briefing schedule for joint settlement approval. "7 2) Should the parties be unsuccessful, Defendant will have up to and including August 18 | 2, 2021 to file its response to Plaintiff's Class Action Complaint. 19 Should the parties need additional time in excess of the stay for reasons related to 20 rescheduling of the mediator, they reserve the right to request additional time from the Court.

28

1 This Stipulation is made in good faith and is not intended for purposes of delay. DATED this 4th day of May, 2021. DATED this 4th day of May, 2021. 3 || BRown, LLC OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 4 5 /s/ Nicholas R. Conlon /s/ Dana B. Salmonson Nicholas R. Conlon (admitted pro hac vice) | Anthony L. Martin 6 | Jason T. Brown (admitted pro hac vice) Nevada Bar No. 8177 111 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 10 | 3800 Howard Hughes Parkway Attorneys for Defendant Wells Fargo Tower, 17th Floor Las Vegas, NV 89169 12 | Attorneys for Plaintiff

te ORDER

15 IT IS SO ORDERED. a RICHA LWARE, II 5 United States District Court DATED this 6th day of May, 2021. 19 20 21 22 23 24 25 26 27 28