1 DANA SNIEGOCKI, ESQ. Nevada Bar No. 11715 2 Email: [email protected] HKM EMPLOYMENT ATTORNEYS LLP 3 101 Convention Center Drive, Suite 600 Las Vegas, Nevada 89109 4 Tel: (702) 805-8340 Fax: (702) 805-8340 5 Attorney for Plaintiff 6

7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 DELIADEM THOMPSON, an individual, Case No.: 2:23-cv-00477-JAD-BNW

10 Plaintiff, STIPULATION AND ORDER TO STAY DISCOVERY PENDING OUTCOME 11 vs. OF EARLY NEUTRAL EVALUATION (FIRST REQUEST) 12 IGNITE TEEN TREATMENT, LLC, a domestic limited liability company and 13 MORIAH BEHAVIORAL HEALTH CO., a domestic corporation; Does I-X and Roe 14 Corporations I-X,

15 Defendants.

16 17 Plaintiff Deliadem Thompson, by and through her counsel, the law firm of HKM 18 Employment Attorneys LLP, and Defendants Ignite Teen Treatment, LLC and Moriah Behavior 19 Health Co., by and through their counsel, the law firm of Jackson Lewis P.C., hereby stipulate and 20 agree to stay discovery pending the outcome of the Early Neutral Evaluation scheduled for 21 November 2, 2023. 22 In assessing a request to stay discovery, the Court decides whether it is necessary to speed 23 the parties along in discovery or whether it is appropriate to delay discovery and spare the parties 24 the associated expense. Tradebay, LLC v. Ebay, Inc.,

(D. Nev. 2011). The 25 parties submit that staying discovery until the Early Neutral Evaluation (“ENE”) will spare both 26 the parties and the Court time and expense. Prior to initiating the instant action, the parties were 27 engaged in settlement discussions, though they were unable to reach a resolution. After the filing 1 || hopeful the ENE will dispense with the need for discovery all together. The parties intend t 9 || continue their settlement discussions during the stay of discovery, if granted. 3 The parties have already met in compliance with Federal Rule of Civil Procedure 26(f), an 4 || have agreed that a stay of discovery is the most prudent course at this juncture. The parties hav 5 || also agreed to exchange initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(1) i 6 || advance of the scheduled ENE. Further, the parties agree that, in the event no settlement is □□□□□□□ 7 || at the ENE, they will submit their Stipulated Proposed Discovery Plan and Scheduling Order, i g || compliance with LR 26-1 on or before November 10, 2023. 10 || DATED this 6th day of September, 2023. 11 HKM EMPLOYMENT ATTORNEYS LLP JACKSON LEWIS P.C. 12 /s/ Dana Sniegocki /s/_ Joshua Sliker 13 || DANA SNIEGOCKI, ESQ. JOSHUA A. SLIKER, ESQ. 14 || Nevada Bar No. 11715 Nevada Bar No. 12493 101 Convention Dr. Suite 600 MICHAEL A. BURNETTE, ESQ. 15 || Las Vegas, NV 89109 Nevada Bar No. 16210 300 S. Fourth Street, Suite 900 16 || Attorney for Plaintiff Las Vegas, Nevada 89101 Deliadem Thompson 17 Attorneys for Defendant 18 Ignite Teen Treatment LLC 19 IT IS SO ORDERED 20 DATED: 9:14 pm, September 07, 2023 21 ru Ls Ween 73 BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28