Hill v. Petco Animal Supplies Stores, Inc.

1 JOSHUA A. SLIKER, ESQ.

Nevada Bar No. 12493 JACKSON LEWIS P.C.

3 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 Telephone: (702) 921-2460 Email: [email protected] Attorney for Defendant Petco Animal Supplies Stores, Inc. UNITED STATES DISTRICT COURT DISTRICT OF NEVADA KISHA HILL, Case No.: 2:23-cv-01002-RFB-VCF 10 Plaintiff, 11 vs. STIPULATION AND ORDER TO: PETCO ANIMAL SUPPLIES STORES, INC., (1) STAY CASE DEADLINES AND a Foreign Corporation Licensed to do Business DISCOVERY PENDING in Nevada, COMPLETION OF EARLY NEUTRAL EVALUATION Defendant. SESSION; AND (2) ESTABLISH CASE DEADLINES 17 Defendant Petco Animal Supplies Stores, Inc. (“Petco” Or “Defendant”), by and through its counsel of record, the law firm of Jackson Lewis P.C., and Plaintiff Kisha Hill (“Plaintiff”), by and through her counsel of record, the Law Office of Mary F. Chapman, Ltd., hereby stipulate and agree as follows: 21 1. Defendant was served with the Summons and Complaint on June 8, 2023, and removed the case to this Court on June 29, 2023 (ECF No. 1).

23 2. The parties are scheduled to participate in an Early Neutral Evaluation Session with Magistrate Judge Brenda Weksler on October 4, 2023 at 10:00 a.m.

25 3. The parties have agreed to continue the deadline for Defendant to file its response to Plaintiff’s Complaint, and to stay case deadlines and discovery pending completion of the ENE so as to conserve the parties’ respective resources and for the sake of judicial economy.

1 4. To that end, the parties agree, that if the case does not resolve at the ENE: (a) Defendant’s response to Plaintiff’s Complaint shall be due by October 18, 2023; and (b) the Joint [Proposed] Discovery Plan and Scheduling Order will be due by October 20, 2023.

4 5. The parties further agree that they are not waiving, relinquishing, or otherwise impairing any claim, defense, argument, or other right they may have by virtue of entering into this Stipulation or participating in the ENE. Szanto v. Marina Marketplace 1, LLC, No. 3:11-cv-00394- RCJ-VPC, 2013 U.S. Dist. LEXIS 168028, at *10 (D. Nev. Nov. 26, 2013).

8 Dated this 8th day of August, 2023.

9 LAW OFFICES OF MARY F. CHAPMAN, JACKSON LEWIS P.C.

LTD. /s/ Mary F. Chapman /s/ Joshua A. Sliker MARY F. CHAPMAN, ESQ. JOSHUA A. SLIKER, ESQ Nevada Bar No. 6591 Nevada Bar No. 12493 8440 W. Lake Mead Blvd., Suite 203 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89128 Las Vegas, Nevada 89101 Attorneys for Plaintiff Kisha Hill Attorneys for Defendant 15 Petco Animal Supplies Stores, Inc. ORDER 17 IT IS SO ORDERED. __________________________ United States District Judge / 20 United States Magistrate Judge 21 Date: ___8_-9_-_2_0_2_3_____________ 4855-0508-2739, v. 1