1 MARGARET A. MCLETCHIE, Nevada Bar No. 10931 LEO S. WOLPERT, Nevada Bar No. 12658 |MCLETCHIE LAW 602 South Tenth Street 3 | |Las Vegas, NV 89101 4 Telephone: (702) 728-5300 Fax: (702) 425-8220 5 | |Email: [email protected] ‘ Counsel for Plaintiff Jessica Halverson

7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 8 9 JESSICA HALVERSON, an individual, Case No.: 2:24-cv-00201-RFB-BNW STIPULATION AND ORDER TO 11| vs. EXTEND DISCOVERY PLAN AND SCHEDULING ORDER 12 | | MISSION SUPPORT AND TEST = 13||SERVICES, LLC, a Delaware limited- SECOND REQUEST liability company. 15 Defendants. y, STATUS OF DISCOVERY. 17 A. PLAINTIFF’S DISCOVERY 18 1. Plaintiffs Initial Disclosures, dated April 9, 2024. 19 B. | DEFENDANTS’ DISCOVERY 20 1. Defendants’ Initial Disclosures, dated April 9, 2024. 21 2. Defendants’ First Set of Requests for Admission, dated May 31, 2024. 22 3. Defendants’ First Set of Requests for Production, dated May 31, 2024. 23 4. Defendants’ First Set of Interrogatories, dated May 31, 2024 24 Il. DISCOVERY THAT REMAINS TO BE COMPLETED. 25 Exchange of written discovery, initial expert disclosures, and depositions. 261) 271) 281)

1 I. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY 2 This is the second request for an extension of discovery deadlines in this matter. 3 | |The Parties request that the Discovery Plan and Scheduling Order deadlines be extended an 4 | |additional sixty (60) days so that the Parties may complete the tasks above. 5 The Parties have been diligently conducting discovery, but an extension is needed 6 | |to efficiently continue to conduct discovery, resolve issues or pursue meet and confer efforts, 7 | janalyze the information provided, and manage the case. The Parties are resolving issues and 8 | |meeting and conferring regarding related issues. Finally, the Parties together request this in 9 | |good faith and to further the resolution of this complicated case on the merits, and not for 10 | Jany purpose of delay. 11 Good cause for this extension particularly exists with regard to amending the 12 | |pleadings and adding parties, as further discovery (and an ENE session) needs to be 13 | |completed before current deadline of August 5, 2024, to determine whether amendment will : 14 | |be needed. 15 Good cause for the extension also exists due to Plaintiff's counsel experiencing 16 | |family medical emergencies, as noted in the first request for an extension of the instant 17 | |deadlines (ECF No. 17.) Following the recent death of Mr. Wolpert’s father in late May of 18 | |2024, Mr. Wolpert has had extensive family obligations as has Ms. McLetchie. Then, on July 19 | |28, 2024, Ms. McLetchie’s mother passed away, requiring her to assist with funeral 20 | jarrangements and attend to her late mother’s affairs and estate. The death has impeded Ms. 21 | |McLetchie’s ability to perform legal work on this and other matters. 22 There is thus good cause for the extension. “Good cause to extend a discovery 23 | |deadline exists ‘if it cannot reasonably be met despite the diligence of the party seeking the 24 | |extension.’” Derosa v. Blood Sys., Inc., No. 2:13-cv-0137-JCM-NJK,

| |108235,

, at 1 (D. Nev. Aug. 1, 2013) (quoting Johnson vy. Mammoth 26 | |Recreations, Inc.,

(9th Cir. 1992)); see also Fed. R. Civ. P. 1 (providing 27 | |that the Rules of Civil Procedure “should be construed, administered, and employed by the 28 | |court and the Parties to secure the just, speedy, and inexpensive determination of every action

1 | Jand proceeding”). The Parties have been diligent in litigating this matter. Thus, the standard 2 | |to extend all deadlines is satisfied here. 3 Based on the foregoing stipulation and proposed deadlines plan, the Parties thus 4 | |respectfully request an extension of time to extend the discovery in this matter to enable to 5 | |them to conduct necessary discovery in this matter and so that this matter is fairly resolved 6 | jon the merits. 7 IV. PROPOSED SCHEDULE FOR REMAINING DEADLINES. 8 Deadline Current Deadline Proposed New Deadline (ECF No. 12) ? Amend Pleadings and | August 5, 2024 October 4, 2024 10 Add Parties Initial Expert September 2, 2024 November 1, 2024 Disclosures 12 Rebuttal Expert October 1, 2024 December 2, 2024! - 2B Disclosures Discovery Cut-Off November 1, 2024 December 31, 2024 4 December 2, 2024 _ | January 31, 2025 15 Joint Pretrial Order? December 31, 2024 | March 3, 2025°

16 Based on the foregoing stipulation and proposed deadlines plan, the Parties request = 17) Ithat the Discovery Plan and Scheduling Order deadlines be extended an additional sixty (60) 18 days so that the parties may conduct necessary discovery. Wy) yyy 1/1

221) 231) 1/1 1/1 26 7 ' 60 days from October 1, 2024 is Saturday, November 30, 2024. ? If a dispositive motion is filed, the Joint Pretrial Order will be filed 30 days after the decision 28 | |on the dispositive motion. > 60 days from December 31, 2024 is Saturday, March 1, 2024.

1 IT IS SO STIPULATED. 2 3 4 DATED this 5™ day of August, 2024. DATED this 5™ day of August, 2024. 5|| MCLETCHIE LAW WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 6 7 By: /s/ Leo S. Wolpert By: /s/ Sheri M. Thome MARGARET A. MCLETCHIE SHERI M. THOME, ESQ. 8 Nevada Bar No. 10931 Nevada Bar No. 8657 LEO S. WOLPERT, JAMES V. LOVETT, ESQ. 9 Nevada Bar No. 12658 Nevada Bar No. 16103 10 602 South Tenth Street 6689 Las Vegas Blvd. South, Suite Las Vegas, Nevada 89101 200 11 Telephone: (702) 728-5300 Las Vegas, Nevada 89119 Fax: (702) 425-8220 Telephone: 702.727.1400 12 [email protected] Fax: 702.727.1401 s 13 Attorneys for Plaintiff Sheri. [email protected] Attorney for Defendant

© 17 IT IS SO ORDERED. 18 19 Leas 20 U.S. DISTRICT COURT MAGISTRATE JUDGE 21 DATED: 8/6/2024 22 23 24 25 26 27 28