1 McCormick, Barstow, Sheppard, Wayte & Carruth LLP 2 Jonathan W. Carlson Nevada Bar No. 10536 3 [email protected] Cheryl A. Grames 4 Nevada Bar No. 12752 [email protected] 5 Chenelle L. Jackson Nevada Bar No. 15750 6 [email protected] 8337 West Sunset Road, Suite 350 7 Las Vegas, Nevada 89113 Telephone: (702) 949-1100 8 Facsimile: (702) 949-1101 9 Attorneys for GEICO CASUALTY COMPANY 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 STEPHEN McCLEAN, an individual, Case No. 2:24-cv-00063-GMN-MDC 14 Plaintiff, 15 STIPULATION AND ORDER TO STAY v. DISCOVERY 16 GEICO CASUALTY COMPANY, a Foreign 17 Limited - Liability Company; DOES I through X, inclusive; and ROE CORPORATIONS I 18 through X, inclusive, 19 Defendants. 20 21 Plaintiff Stephen McClean and Defendant GEICO Casualty Company (“GEICO”), by and 22 through their respective counsel of record, hereby stipulate to stay discovery until after this Court’s 23 ruling on Defendant’s Motion to Dismiss (Doc. 7). The parties believe that conducting discovery 24 that specifically concerns Plaintiff’s extra-contractual claims at this time would not be in the best 25 interests of the parties. The parties believe that a stay of discovery is appropriate in this case under 26 the two-step analysis in Scharder v. Wynn, No. 2:19-cv-02159-JCM-BNW,

, at 27 *4 (D. Nev. Oct. 14, 2021). In addition, a stay would accomplish the objectives of Rule 1: a just, 1 || will grant Defendant’s Motion, making all such discovery moot. However, absent a stay the parties 2 || would be compelled to conduct this discovery on the extra-contractual causes of action that are the 3 || subject of the pending Motion, in order to meet applicable discovery deadlines. The parties further 4 || stipulate that they will submit a proposed discovery plan and scheduling order within twenty-one 5 || (21) days of the entry of the Court’s ruling on Defendant’s Motion to Dismiss (Doc. 7). 6 ORDER 7 IT IS HEREBY ORDERED that discovery in this case is stayed until after the entry of this 8 || Court’s ruling on Defendant’s Motion to Dismiss (Doc. 7). 9 IT IS RESPECTFULLY SUBMITTED, AGREED, AND STIPULATED. 10 || Dated: March 8, 2024 McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP

12 By: /s/ Jonathan W. Carlson B Jonathan W. Carlson, Nevada Bar No. 10536 Cheryl A. Grames, Nevada Bar No. 12752 14 Chenelle L. Jackson, Nevada Bar No. 15750 Attorneys for GEICO Casualty Company 15 16 || Dated: March 8, 2024 THE702FIRM INJURY ATTORNEYS 17 By: /s/ Matthew P. Pawlowski 18 Michael C. Kane, Nevada Bar No. 10096 19 Bradley J. Myers, Nevada Bar No. 8857 Matthew P. Pawlowski, Nevada Bar No. 9889 20 Attorneys for Plaintiff 2] ORDER 2 IT IS SO ORDERED. . “4 □□□ . 11th March fff □ 53 DATED this" day of 2024 ZA a ff A ix 24 I, fo APN # □ By jf fo f tf 26 UNFIED STATES MAGISTRATE JUDGE 27 9733360.1 9731183.1 28 BARSTOW, WAYTE & a cs ue mt ™éA NAAN □□□□□□□□□□□□□□□□

1 CERTIFICATE OF SERVICE 2 I hereby certify that on this 8th day of March, 2024, a true and correct copy 3 of STIPULATION AND ORDER TO STAY DISCOVERY was served via the United States 4 District Court CM/ECF system on all parties or persons requiring notice. 5 6 By /s/ Cheryl A. Schneider Cheryl A. Schneider, an Employee of 7 McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27