1 MARI K. SCHAAN, ESQ. Nevada Bar No. 11268 2 NATHAN R. REINMILLER, ESQ. Nevada Bar No. 6793 3 HALL PRANGLE & SCHOONVELD, LLC 1140 North Town Center Drive, Ste. 350 4 Las Vegas, Nevada 89144 (702) 889-6400 – Office 5 (702) 384-6025 – Facsimile 6 Email: [email protected] Attorneys for Defendant Aosom, LLC 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 PHILIP ALEXANDER, individually, CASE NO. 2:22-cv-01715-GMN-BNW 10 Plaintiffs, vs. 11 [PROPOSED] JOINT DISCOVERY AOSOM, LLC., Foreign Limited-Liability 12 Company; WALMART INC., a Foreign PLAN AND SCHEDULING ORDER Corporation; DOES I through X, inclusive; and 13 ROE BUSINESS ENTITIES I through X, inclusive, SUBMITTED IN COMPLIANCE 14 WITH LR 26-1(b) Defendants. 15 16 17 Plaintiff, PHILIP ALEXANDER and Defendants AOSOM, LLC and WALMART INC, 18 by and through their undersigned counsel hereby submit the Proposed Stipulated Discovery Plan 19 and Scheduling Order pursuant to Local Rule 26-1(a). The scheduling order is in compliance 20 with Local Rule 26-1(a). 21 This action was initiated in the Eighth Judicial District Court, County of Clark on 22 September 2, 2022. Defendant Walmart filed an Answer to the Complaint on September 30, 23 2022. AOSOM, LLC filed Petition for Removal from the State Court on October 11, 2022 and 24 an Answer on October 18, 2022. Pursuant to Fed. R. Civ. P. 26(f) and LR26-1(a), on October 25 31, 2022, counsel for the parties met and conferred regarding the Discovery deadlines in the 26 above-captioned matter. John Shook of the Law Offices of Shook and Stone, appeared on behalf 27 of the Plaintiff, Philip Alexander; Nathan Reinmiller of Hall, Prangle and Schoonveld LLC 28 appeared on behalf of the Defendant AOSOM, LLC and Madison Aguirre of Alverson Taylor 1 appeared on behalf of Walmart, Inc.. During the conference, counsel for the parties discussed 2 and agreed upon the following: 3 PROPOSED SCHEDULE 4 1. Discovery shall be completed on or before March 29, 2023 (180 days from the date of 5 Defendant Walmart’s answer); 6 2. Motions to amend, or to add parties, shall be filed and served on or before December 7 29, 2022; 8 3. Expert disclosures pursuant to Fed. R. civ. P. 26(a)(2) shall be made on or before 9 January 28. 2023; 10 4. Rebuttal expert disclosures shall be made on or before February 27, 2023; 11 5. Dispositive motions shall be filed and served on or before April 28, 2023; 12 6. The Joint Pre-trial Order shall be filed on or before May 28, 2023. In the event 13 dispositive motions are filed, the date for filing the Joint Pre-trial Order shall be suspended until 14 30 days after the decision on the dispositive motions or further Order of the Court (LR26- 15 1(b)(5)); 16 7. The disclosures required by Fed. R. Civ. P. 26(a)(3) and any objections thereto shall 17 be included in the pretrial order; and 18 8. Any request to extend the dates set forth in this Discovery Plan and Scheduling Order 19 shall be submitted to the Court not later than 21 days before the expiration of the subject 20 deadline sought to be extended. 21 INITIAL DISCLOSURES AND DISCOVERY 22 The parties anticipate having their initial disclosures delivered to each other within 23 fourteen days of the conference, or November 14, 2022. The Parties anticipate conducting 24 written discovery and depositions on all issues allowed under the Federal Rules of Civil 25 Procedure. (Fed. R. Civ. P. 29(f)(3)(B)). There are currently no issues which parties are aware of 26 regarding discovery of electronically stored information or claims of privilege/protection of trial 27 preparation materials. (Fed. R. Civ. P. 26(f)(3)(C). There are currently no issues which the 28 parties are aware of regarding claims of privilege, but the parties anticipate that, to the extent 1 || that disclosure of certain sales, marketing, and financial information is necessary during the 2 ||course of discovery, the parties will be discussing and submitting a proposed stipulated 3 || protective order requiring that such information that is disclosed during discovery be kept 4 ||confidential pursuant to the discovery rules. (Fed. R. Civ. P. 26(f)(3)(D)). The parties also 5 || anticipate the need to establish protocols concerning any destructive testing of the equipment 6 || that may be necessary. 7 DATED this 7" day of November, 2022. 9 SHOOK & STONE, CHTD. ALVERSON TAYLOR & SANDERS 10 || 4s/ John Shook /s/ Madison Aguirre S John B. Shook, Esq. Kurt R. Bonds, Esq. || Lynn R. Shoen, Esq. Patrice Stephenson-Johnson, Esq. 3 ||

" Street Madison Aguirre, Esq. Las Vegas, Nevada 89101 6605 Grand Montecito Parkway, Ste. 200 13 || Attorney for Plaintiff Las Vegas, Nevada 89149 g Attorney for Defendant Walmart 14 HALL PRANGLE & SCHOONVELD, LLC

16 ||8/Nathan Reinmiller MARI K. SCHAAN, ESQ. 17_|| Nevada Bar No. 11268 NATHAN R. REINMILLER, ESQ. ig || Nevada Bar No. 6793 1140 North Town Center Drive, Ste. 350 19 || Las Vegas, Nevada 89144 Attorneys for Defendant AOSOM, LLC 20 21 ORDER IT IS ORDERED that ECF No. 9 is GRANTED. 23 IT IS FURTHER ORDERED that the parties must file a supplement to their 24 discovery plan and scheduling order by 11/11/2022 in compliance with LR 26-1(b)(7)-(9). 25 IT IS SO ORDERED 6 DATED: 4:44 pm, November 08, 2022 a7 BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 28