1 || CHRISTINE M. BOOZE Nevada Bar No. 7168 2 || RACHEL L. SHELSTAD Nevada Bar No. 13399 3 || WINNER & BOOZE 1117 South Rancho Drive 4 | Las Vegas, Nevada 89102 Phone (702) 243-7000 5 || [email protected] [email protected] 6 || Attorneys for Defendant State Farm Mutual 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA JOANNE LIU and WESLEY CHONG, CASE NO.: 2:22-cv-00099- CDS-VCF 10 Plaintiffs, 11 VS. =|) 12 STATE FARM MUTUAL AUTOMOBILE 13 | INSURANCE COMPANY, and DOES I through X, inclusive, 14 Defendants. 16 STIULATION AND ORDER TO EXTEND DISCOVERY 17 | 18 (Second Request) 19 Defendant STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by 20 || and through its attorneys, Christine M. Booze and Rachel L. Shelstad of the law firm WINNER 21 || & BOOZE, and Plaintiffs JOANNE LIU and WESLEY CHONG, by and through their attorney, 22 || Robert E. Marshall, of the MARSHALL LAW OFFICE, hereby submit the following Stipulation 23 || and (Proposed) Order to Extend Discovery pursuant to LR 26-4 LR IA 6-1. 24 This is the second stipulation for an extension of discovery deadlines. 25 A. Discovery Completed Plaintiffs have served their initial FRCP disclosure of witnesses and documents, and one 27 || supplement thereto. 28 Defendant has served its initial FRCP disclosure of witnesses and documents and Page 1 of 4

1 || fourteen supplements thereto. 2 Plaintiffs have served their initial Expert Witness Designation. 3 Defendant has served its initial Expert Witness Designation and two supplements thereto. 4 Defendant has served its initial Rebuttal Expert Witness Designation and one supplement 5 || thereto. 6 Defendant has served one set of Interrogatories and one set of Requests for the 7 || Production of Documents to Plaintiff, which have been answered. 8 Plaintiff has served one set of Interrogatories, one set of Requests for the Production of 9 || Documents to Defendant, which have been answered. 10 Defendant has deposed Plaintiffs’ multiple medical doctors: bt) 11 e Dr. Antonino Gumina; | 12 e Dr. Nancy Hsiao g 13 e Dr. David Lanzkowky; ab 14 e Dr. Enrico Fazzini; 4 15 e Dr. Inchol Yun; S| 16 e Dr. Russell Glassman. S| 7 Defendant has taken the Examination Under Oath of Plaintiff Joanne Liu, volumes I and ag fon 19 Defendant has taken the Examination Under Oat of Plaintiff Wesley Chong, volume I. 20 Multiple Subpoena Duces Tecum have been served upon plaintiff's medical providers in 21 || order to obtain the medical records of plaintiffs Joanne Liu and Wesley Chong. 22 Discovery that Remains to Be Completed 23 Videotaped deposition of plaintiff Joanne Liu. 24 Videotaped deposition of plaintiff Wesley Chong. Mr. Chong’s deposition is scheduled 25 || and set to take place on 1/24/2023. 26 Experts will need to review new medical records and supplement their reports. 27 Plaintiff reserves the right to depose the Defendant’s medical experts. 28 Page 2 of 4

1 B. The Reasons Why Discovery Was Not Completed In the Time Limits Set by the 2 Discovery Plan 3 Coordinating a date for the Plaintiff Joanne Liu’s deposition. 4 Counsels for both parties are attempting to schedule the date, in which Plaintiff Joanne 5 Liu’s deposition can be conducted. 6 A 30-day extension of discovery is respectfully requested to permit the deposition and to 7 permit experts to complete supplemental reports based on their review of medical 8 records. 9 C. Proposed Schedule for Completing Discovery 10 The parties propose to complete discovery on the following deadlines: dU e Discovery Cut-Off: March 9, 2023

N 12 e Deadline to Disclose Initial Experts: No Extension Requested | 13 e Deadline to Disclose Rebuttal Experts: No Extension Requested fad | If dispositive motions are file wh 14 * Deadline to File Dispositive Motions: April 10, 2023 _ the deadline for filing the join i pretrial order will be suspend 15 e Deadline to File Joint Pre-Trial Order May 10, 2023 until 30 days after decision or dispositive motions or furthe: £. | ~ 16 □ court order. 17 || DATED this 23" day of January, 2023. DATED this 23 day of January, 2023. 18 | WINNER & BOOZE MARSHALL LAW OFFICE 19 20 /s/ Rachel L. Shelstad eo BLE By: By: _ 21 Rachel L. Shelstad Robert E. Marshall 22 || Nevada Bar No. 13399 Nevada Bar No. 4327 93 || 1117S. Rancho Drive

" Street Las Vegas, NV 89102 Las Vegas, NV 89101 24 || Tel: (702) 243-7000 Tel: (702) 474-000 For the Defendant For the Plaintiffs 25 26 IT IS SO ORDERED. 27 Load ote. Cam Ferenbach Page 3 of 4 United States Magistrate Judge