H. v. Boyd Gaming Corp.

1 KEMP JONES, LLP Michael Gayan Nevada Bar No. 11135 [email protected] 3800 Howard Hughes Parkway 17th Floor Las Vegas, Nevada 89169 Tel: 702.385.6000 Fax: 702.385.6001 DLA PIPER LLP (US) David S. Sager (admitted pro hac vice) John F. Kennedy Parkway, Suite 120 Short Hills, New Jersey 07078 T: 973.520.2550 | F: 973.520.2551 [email protected] Kyle T. Orne (admitted pro hac vice) 2525 East Camelback Road, Suite 1000 Phoenix, AZ 85016 T: 480.606.5100 | F: 480.606.5101 [email protected] Attorneys for Defendant Venetian Las Vegas Gaming, LLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA CATELYN H., pseudonymously, Cas e No. 2:24-cv-00939-JCM-DJA 19 Plaintiff, STIPULATION AND ORDER TO STAY DISCOVERY v. VENETIAN LAS VEGAS GAMING, LLC, BOYD GAMING CORP., and THE MIRAGE CASINO – HOTEL, LLC, Defendants.

1 Plaintiff CATELYN H. and Defendants VENETIAN LAS VEGAS GAMING, LLC (“Venetian”), BOYD GAMING CORP. (“Boyd”), and THE MIRAGE CASINO – HOTEL, LLC (“Mirage”) (collectively the “Parties”), by and through their respective counsel of record, hereby agree and stipulate as follows: 5 On July 11, 2024, Plaintiff filed her first amended complaint (ECF No. 55). On July 25, 2024, Venetian, Boyd, and Mirage filed motions to dismiss Plaintiff’s first amended complaint (ECF Nos. 57-59). On August 15, 2024, Plaintiff filed her response to the various motions to dismiss her first amended complaint (ECF No. 66).

9 In the interests of judicial economy and to avoid incurring potentially unnecessary attorneys’ fees and costs, the Parties agree that discovery should be stayed pending the Court’s ruling on the aforementioned Motions to Dismiss. Good cause exists for a stay of discovery. First, the Motions to Dismiss are still pending before this Court, and no fact discovery is needed to resolve these Motions seeking the complete dismissal of Plaintiff’s Complaint. Additionally, any discovery in this case would involve the production of records involving a Plaintiff who alleges she is a survivor of human trafficking. Plaintiff believes that maintaining her privacy is crucial at this point, and any stay would obviate the need for a disclosure of her identity until the pending Motions to Dismiss are decided. Any discovery would necessarily involve highly sensitive documents related to Plaintiff, including her identity.

19 A stay while the Motions to Dismiss are pending is therefore consistent with this Court’s holding in Schrader v. Wynn Las Vegas, LLC, No. 2:19-cv-02159, 2021 WL 4810324 (D. Nev. Oct.

21 14, 2021), as it will maximize Plaintiff’s interest in maintaining her privacy, as well as conserve judicial resources and avoid unnecessary costs. See id. at *5 (granting stay motion because a party “demonstrated harm or prejudice will result if discovery proceeds now” and “good cause exists to continue the stay of discovery”); see also Order Granting Stipulation to Stay Discovery, C.C. v. Rashid et al., No. 2:23-cv-02056 (D. Nev. Apr. 30, 2024), ECF No. 96 (staying case with similar human trafficking allegations pending the Court’s decision on pending motions to dismiss); Order Granting Stipulation to Stay Discovery, S.C. v. Hilton Franchise Holding LLC et al., No. 2:23-cv- 02037 (D. Nev. May 6, 2024), ECF No. 52 (same).

3 To the extent that the Court’s decisions on the Motions to Dismiss do not fully dispose of this matter, the Parties agree that a discovery plan and proposed scheduling order shall be due within thirty (30) days of the Court’s decision on the Motions to Dismiss.

6 The Parties further discussed and intend to propose a one (1) year discovery period commencing as of the date of the Court’s ruling on the Motions to Dismiss.

8 IT IS SO STIPULATED.

9 Dated: September 10, 2024 KEMP JONES LLP KEMP JONES LLP By: /s/ Michael Gayan___________________ By: /s/ Michael Gayan__________________ Michael Gayan Michael Gayan [email protected] [email protected] DLA PIPER LLP (US) DLA PIPER LLP (US) David S. Sager (admitted pro hac vice) Ellen Elizabeth Dew (admitted pro hac vice) John F. Kennedy Parkway, Suite 120 Sima G. Fried (admitted pro hac vice) Short Hills, New Jersey 07078 650 S Exeter Street Suite 1100 16 Baltimore, Maryland 21202-4576 Kyle T. Orne (admitted pro hac vice) Attorneys for Defendant The Mirage Casino 2525 East Camelback Road, Suite 1000 – Hotel, LLC Phoenix, AZ 85016 Attorneys for Defendant Venetian Las Vegas Gaming, LLC / / / / / / / / / |) HILTON PARKER LLC COVINGTON & BURLING LLP || By: /s/ Geoffre Parker By: /s/Neil Roman Geoffrey Parker, Esq. (admitted pro hac vice) Nei] Roman, Esq. (admitted pro hac vice) 7658 Slate Ridge Blvd. Edward Rippey, Esq. (admitted pro hac vice) || Reynoldsburg, OH 43068 One CityCenter Attorney for Plaintiff 850 Tenth Street, NW 5 Washington, DC 20001 6 Todd L. Bice, Esq., Bar No. 4534 7 [email protected] Emily A. Buchwald, Esq., Bar No. 13442 8 [email protected] Alexandra N. Mateo, Esq., Bar No. 16275 ? PISANELLI BICE PLLC 10 400 South 7th Street, Suite 300 Las Vegas, Nevada 89101 11 Attorneys for Defendant Boyd Gaming Corporation || ITISSO ORDERED.

17 || DATED: 9/12/2024 18 □□ .

DANIEL J. ALBREGTS || UNITED STATES MAGISTRATE JUDGE