, || PETER S. CHRISTIANSEN, ESQ. Nevada Bar No. 5254 2 || [email protected] R. TODD TERRY, ESQ. 3 || Nevada Bar No. 6519 [email protected] 4 || WHITNEY J. BARRETT, ESQ. Nevada Bar No. 13662 5 || [email protected] CHRISTIANSEN TRIAL LAWYERS 6 ||

" Street, Suite B Las Vegas, Nevada 89101 7 || Telephone: (702) 240-7979 Facsimile: (866) 412-6992 8 || Attorneys for Plaintiff ? DISTRICT COURT

| 10 CLARK COUNTY, NEVADA 1] Dv LISTON M. GOODMAN, an Individual; 7 CASE NO. 2:22-cv-24 = B Plaintiff, < — 14 VS. STIPULATION AND ORDER TO EXTEND 15 DISCOVERY DEADLINES PANDA EXPRESS, INC. d/b/a PANDA 16 EXPRESS, a Foreign Corporation; PANDA (SECOND REQUEST) RESTAURANT GROUP, INC. d/b/a PANDA 17 EXPRESS, A Foreign Corporation; DOE PANDA EXPRESS EMPLOYEES; DOES I through XX, 18 inclusive; and ROE BUSINESS ENTITIES I 7 19 through XX inclusive, Defendants. 20 21 . IT IS HEREBY STIPULATED by and between the parties hereto and their respectiv 22 counsel of record, as follows: 23 1. DISCOVERY COMPLETED 24 1. A Rule 36(f) Case Conference was held and a Discovery Plan/Scheduling Orde 25 was filed. 26 47 2. Plaintiffs have disclosed their initial disclosures and three supplements thereto; 28 3. Defendant has disclosed its initial disclosures;

1 4. The parties have propounded and responded to written discovery requests; 2 5. Plaintiffs deposition was taken on April 11, 2022; and 3 6. Troy Russell, MD’s deposition was taken on June 14, 2022. 4 Il. DISCOVERY TO BE COMPLETED 5 1. Plaintiff will take the deposition(s) of Defendant’s corporate designees pursuan 6 to FRCP 30(b)(6) on July 11, 2022; 2. The parties will depose Steven Olenchak, PA on July 7, 2022; 3. The parties will depose Defendant’s employees; ° 4. The parties will disclose expert witnesses and depose their respective experts; | 5. The parties intend to serve, and respond to, additional written discovery; D 6. The parties intend to conduct the depositions of other parties, fact witnesses B Plaintiff's treating providers, and the parties’ experts; and 14 7. The parties intend to supplement numerous expert witnesses and reports. Il. REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETEI 0 I5 WITHIN THE TIME LIMITS PROVIDED BY THE SCHEDULING ORDER | 16 Counsel has been working diligently to adhere to the current discovery deadline: 17 |) however; additional time is needed to take depositions and designate experts. The parties ar / 18 currently attempting to schedule mediation with Retired Judge Trevor L. Atkin. In order t 19 |) facilitate a private mediation and avoid potentially unnecessary expert fees, the parties hav 20 agreed to continue the discovery deadlines sixty (60) days. 21 IV. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY: □□ (oT ERISTING DEADLINES EROROSED DEADLINES

25 ey

] Final Date fe nae er September 19, 2022 November 18, 2022 2 Dispositive Motions 3 Pretrial Order October 20, 2022 December 19, 2022 5 ||} ITIS SO STIPULATED. 6 CHRISTIANSEN TRIAL LAWYERS WILSON ELSER MOSKOWITZ 7 EDELMAN & DICKER, LLP 9 /s/ Peter §. Christiansen _/s/ Kevin A. Brown ___ PETER S. CHRISTIANSEN, ESQ. MICHAEL P. LOWRY, ESQ. 19 || Nevada Bar No. 5254 Nevada Bar No. 10666 | R. TODD TERRY, ESQ. KEVIN A. BROWN, ESQ. 1 || Nevada Bar No. 6519 Nevada Bar No. 7621 WHITNEY J. BARRETT, ESQ. 12 || Nevada Bar No. 13662 6689 Las Vegas Blvd. South, Suite 200 > 710 South 7® Street Las Vegas, NV 89119 13 || Las Vegas, Nevada 89101 Attorney for Defendants — 14 Attorneys for Plaintiff = 15 ORDER 16 | 7 Based on the foregoing stipulation, and good cause appearing: IT IS SO ORDERED. 19 / me) Dalh 20 United States ‘istrate’ Judge 21 Dated: June 16, 2022 22 23 24 25 26 27 28