1 ROBERT T. EGLET, ESQ. Nevada Bar No. 3402 9 || TRACY A. EGLET, ESQ. Nevada Bar No. 6419 3 || DANIELLE C. MILLER, ESQ. Nevada Bar No. 9127 4 || EGLET ADAMS 400 S. Seventh St., Suite 400 5 || Las Vegas, NV 89101 (702) 450-5400; Fax: (702) 450-5451 6 || eservice @egletlaw.com -and- 7 || MATTHEW L. SHARP, ESQ. Nevada Bar No. 4746 8 || MATTHEW L. SHARP, LTD. 432 Ridge Street ? || Reno, NV 89501 10 (775) 324-1500; Fax: (775) 284-0675 Attorneys for Plaintiff 11 D UNITED STATES DISTRICT COURT B DISTRICT OF NEVADA 14 || ELIZABETH GARRIDO, individually and on behalf of all those similarly situated, Case No.: 2:21-cv-00440- RFB-BNW 15 16 Plaintiff, STIPULATION AND PROPOSED vs. ORDER EXTENDING — 17 DEADLINE FOR PLAINTIFF TO FARMERS AUTOMOBILE INSURANCE FILE AMENDED COMPLAINT ASSOCIATION, FARMERS — INSURANCE 19 EXCHANGE, DOES 1 through 10, 20 Defendants. 21 Plaintiff ELIZABETH GARRIDO, by and through their counsel of record, Robert T 22 || Eglet, Esq., Tracy A. Eglet, Esq., and Danielle C. Miller, Esq. of the law firm EGLET ADAM: 23 || and Matthew L. Sharp, Esq. of the law firm MATTHEW L. SHARP, LTD., and Defendan 24 || FARMERS INSURANCE EXCHANGE (“Farmers”), by and through their counsel of record 25 || Vanessa Wells and Jordan Teti of HOGAN LOVELLS US LLP, Jordan T. Smith, Esq., and M 26 || Magali Mercera, Esq., of the law firm PISANELLI BICE PLLC, for good cause shown, hereb 27 || stipulate and agree as follows: 28 1. Plaintiff filed her Complaint in the Eighth Judicial District Court for Clark County Nevada, Case No. A-21-829905-B. Farmers removed this action to this Court on March 17, 2021

1 2. Farmers filed their Motion to Dismiss on May 14, 2021 [ECF No. 20]. 2 3. Plaintiff filed her Response to Farmers’ Motion on June 14, 2021 [ECF No. 24]. 3 4. Farmers filed a Reply in support of the Motion on July 9, 2021 [ECF No. 26]. 4 5, On February 9, 2021, the Honorable Richard F. Boulware, II granted Farmer’ 5 || Motion to Dismiss with prejudice, except that the Court granted leave to amend as to the Third 6 || Fourth, and Fifth Causes of Action to the extent Plaintiff is able to amend consistent with th 7 || Court’s decision. The Court designated the transcript of the hearing as the written decision in th 8 || matter. The Court allowed s and Ordered Plaintiff 30 days to file an Amended Complaint (on o 9 || before Friday, March 11, 2022) [ECF No. 30]. DY 10 6. At the hearing, the District Court expressly encouraged the parties to be courteou 11 || with extensions for issues related to the contemplated amended complaint. 12 7. Because the three claims that were dismissed without prejudice must be pled □□□ 13 || particularity, if possible, Plaintiff needs additional time to review Plaintiff's e-mai 14 || correspondence, records, and bank statements going back at least two (2) years, to the beginnin; 15 || of the COVID-19 pandemic. Given how much time has passed and given the burden of pleadin; 16 || Plaintiff's claims with particularity, Plaintiff needs additional time to thoroughly review he 17 || records to obtain this information. Plaintiff will also have to request some of this informatio: 18 || from third parties, which may take additional time. 19 8. Thus, the parties hereby stipulate that Plaintiff shall have an additional sixty (60 20 || days to file an Amended Complaint. 21 9. That Plaintiff's Amended Complaint shall be due on or before May 11, 2022. 22 10. Farmers shall have an additional thirty (30) days to file its response to Plaintiff 23 || Amended Complaint, extending the time to respond under the Federal Rules of Civil Procedur 24 || from fourteen (14) days after service of the Amended Complaint to forty-four (44) days afte 25 || service of the Amended Complaint. Farmers anticipates needing this additional time to respon: 26 || to the additional factual information that Plaintiff must include in the amended complaint. 27 11. The parties agree that discovery remains stayed pending Plaintiff filing a 28 || Amended Complaint and resolution of Defendant’s anticipated Motion to Dismiss Plaintiff

1 |} Amended Complaint. 2 12. In this District, requests to stay discovery may be granted when: (1) the pendin; 3 || motion is potentially dispositive; (2) the potentially dispositive motion can be decided withou 4 || additional discovery; and (3) the Court has taken a “preliminary peek” at the merits of th 5 || potentially dispositive motion. Tradebay, LLC v. eBay, Inc.,

(D. Nev. 2011) 6 || In doing so, the court must consider whether the pending motion is potentially dispositive of th 7 || entire case, and whether that motion can be decided without additional discovery. See Federc 8 || Housing Finance Agency v. GR Investments LLC, Case No. 2:17-cv-03005-JAD-EJY ,

|| 2798011 at *3 (D. Nev. May 29, 2020) (granting motion to stay discovery pending resolution o DY 10 || potentially dispositive motion for summary judgment); see also Mintun v. Experian Informatio 11 || Solutions, Inc., 2:19-cv-00033-JAD-NJK,

at **1-2 (D. Nev. May 15, 2019 12 □□ (granting motion to stay discovery pending resolution of potentially dispositive motion t 13 |} dismiss). 14 13. The Parties agree that Farmers’ Motion to Dismiss raises potentially dispositiv 15 || legal and jurisdictional defenses to Plaintiff’s claims concerning Farmers’ auto insurance rate 16 || during the COVID pandemic. 17 14. The Court previously stayed discovery pending Farmers’ initial motion to dismiss 18 || [ECF No. 12.] The same considerations are present with the expected motion to dismiss th 19 || amended complaint. 20 15. Pending resolution of Farmers’ Motion to Dismiss, the Parties agree and stipulat 21 || to a stay of discovery including, but not limited to, any discovery obligations set forth in Fed. R 22 || Civ. P. 26 and LR 26-1. 23 16. If the Court denies Farmers’ Motion to Dismiss, in whole or in part, the Partie 24 || agree to submit a Discovery Plan and Scheduling Order within thirty (30) days after entry of th: 25 || Court’s Order on the Motion. 26 17. The parties respectfully suggest that good cause exists to enter the stipulated sta 27 || of discovery to preserve judicial and party resources and based on application of the factors se 28 || forth in paragraph 11, above.

1 18. The Parties represent that this stipulation is sought in good faith, is not interpose 2 || for delay, and is not filed for an improper purpose. 3 DATED this 10th day of March, 2022. DATED this 10th day of March, 2022. EGLET ADAMS PISANELLI BICE PLLC 6 Robert T. Eglet, Esq. __ /s/ Jordan T. Smith, Esq. ROBERT T. EGLET, ESQ. JORDAN T. SMITH, ESQ. 7 || Nevada Bar No. 3402 Nevada Bar No. 12097 DANIELLE C. MILLER, ESQ. M. MAGALI MERCERA, ESQ. Nevada Bar No. 9127 , TRACY A. EGLET, ESQ. RYAN ES 9 || Nevada Bar No. 6419 □ D ’ 4 Q 19 || 400 S. Seventh St., Suite 400 Moo en my mee 3 e300 LY ou reet, Suite Wl Las veges. 89101 Las Vegas, NV 89101 -and- D MATTHEW L. SHARP, ESQ. VANESSA O WELLS, ESQ. Nevada Bar No. 4746 (admitted pro hac vice) 13 MATTHEW L. SHARP, LTD. HOGAN LOVELLS US LLP < 432 Ridge Street 4085 Campbell St., Ste 100 14 || Reno, NV 89501 Menlo Park, CA 94025 5 Attorneys for Plaintiff Attorneys for Defendants

16 ORDER et 17 Based upon the parties’ stipulation and GOOD CAUSE APPEARING THEREFOR, I 18 IS SO ORDERED: 19 IT IS SO ORDERED. 20 21 K pn la WER 22 UNITED STATES MAGISTRATE JUDGE 23 DATED: March 11, 2022 24 25 26 27 28