1 | HATTIS & LUKACS DANIEL M. HATTIS 2 (admitted pro hac vice) 3

" Street, Street 120 Bellevue, Washington 98005 (425) 233-8650 Email: [email protected] 5 | Email: [email protected] 6 [additional counsel listed under signature line] 7 Attorneys for Plaintiffs and the Proposed Class 8 DICKINSON WRIGHT PLLC 9 | MICHAEL N. FEDER 10 NV Bar No. 7332 GABRIEL A. BLUMBERG 11 | NV Bar No. 12332 3883 Howard Hughes Parkway, Suite 800 12 | Las Vegas, Nevada 89169 Tel: 702-550-4400 13 844-670-6009 14 Email: [email protected] Email: [email protected] 15 [additional counsel listed under signature line] 16 Attorneys for Defendant CoxCom, LLC

18 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 19 Linda Fallica and Case No. 2:24-cv-02222-APG-BNW 20 || Cheri Woods, on behalf of themselves STIPULATION AND PROPOSED ORDER 21 | and all others similarly situated, TO STAY DEFENDANT’S OBLIGATION TO RESPOND TO COMPLAINT AND TO 22 Plaintiffs, ESTABLISH BRIEFING SCHEDULE FOR 3 DEFENDANT’S MOTION TO COMPEL v. RBITRATION 24 CoxCom, LLC, (FIRST REQUEST) 2 Defendant. 26 27 28

1 STIPULATION 2 IT IS HEREBY STIPULATED AND AGREED between Plaintiffs Linda Fallica and Cheri Woods (“Plaintiffs”) and Defendant CoxCom, LLC (“Defendant”) (collectively, the “Parties”), by and through their respective counsel and pending the Court’s approval, as follows: ° 1. The current deadline for Defendant to respond to the Complaint is February 3, ° 2025 (ECF No. 17), at which time Defendant intends to file a Motion to Compel Arbitration. ' 2. Staying Defendant’s Deadline To Respond To Complaint. The Parties agree ° that Defendant’s deadline to respond to the Complaint be stayed until thirty (30) days after the Court decides Defendant’s Motion to Compel Arbitration, if necessary. 3. Good cause exists for the stay set forth herein. The Parties believe it will be most

efficient if Defendant’s to-be-filed Motion to Compel Arbitration is adjudicated before

Defendant files a response (likely a motion to dismiss) to the Complaint. The outcome of Defendant’s Motion to Compel Arbitration may obviate the need for any subsequent filing or

15 may otherwise affect the claims in the litigation before this Court. If Defendant’s response has

6 already been filed, a ruling on the Motion to Compel Arbitration may result in the need to file a

7 new or modified response to the Complaint. Therefore, to promote judicial efficiency and save

18 resources, the Parties jointly ask that Defendant’s deadline to respond to the Complaint be stayed 19 until after the Court has ruled upon Defendant’s Motion to Compel Arbitration. See Clinton v.

U.S. 681, 706 (1997) (“The District Court has broad discretion to stay proceedings as

54 an incident to its power to control its own docket.”); Calkins v. Credit One Bank, N.A., No. 2:16-

CV-2602-APG-NJK,

, at *1 (D. Nev. Mar. 10, 2017) (granting motion to stay 5 action pending resolution of motion to compel arbitration). 4. This 1s the Parties’ first such request for a stay of this action. This request 1s made

5 in good faith and is not intended for purposes of delay 5. Briefing Schedule on Motion to Compel Arbitration. The Parties agree that the briefing schedule on the to-be-filed Motion to Compel Arbitration be extended since the arguments for and against the Motion to Compel Arbitration may be complex. The Parties are also attempting to stagger and coordinate the briefing in this civil action with briefing that will

1 | occur in other civil actions in which counsel for Plaintiffs and counsel for Defendant are 2 | mutually involved. In addition, Plaintiffs’ counsel Paul Karl Lukacs, Esq., resides in Los 3 | Angeles, where the recent fires have disrupted daily life. 4 6. As such, the Parties respectfully request that Defendant’s Motion to Compel 5 | Arbitration be briefed in accordance with the following schedule: 6 a. February 3, 2025 - Defendant files its Motion to Compel Arbitration 7 b. March 31, 2025 - Plaintiffs file their Opposition to the Motion to Compel 8 Arbitration 9 c. April 21, 2025 - Defendant files its Reply in support of the Motion to 10 Compel Arbitration. 11 7. This is the Parties’ first request to extend the time in which to brief Defendant’s 12 | impending Motion to Compel Arbitration. This request is made in good faith and 1s not intended 13 14 15 16 17 18 19 20 // 21 22 23 24 25 26 27 28

.

1 | for purposes of delay. 2 Dated: January 16, 2025. Dated: January 16, 2025. 3 HATTIS & LUKACS DICKINSON WRIGHT PLLC 4 /s/ Paul Karl Lukacs /s/Michael N. Feder 5 | Daniel M. Hattis Michael N. Feder 6 (admitted pro hac vice) NV Bar No. 7332 Paul Karl Lukacs Gabriel A. Blumberg 7 || (admitted pro hac vice) NV Bar No. 12332

" Street, Street 120 3883 Howard Hughes Parkway, Suite 800 8 || Bellevue, Washington 98005 Las Vegas, NV 89169 9 | DENITTIS OSEFCHEN PRINCE, P.C BLANK ROME LLP 10 Stephen P. DeNittis Evan H. Lechtman (admitted pro hac vice) PA Bar No. 89845 11 || 5 Greentree Centre, Suite 410 (pro hac vice forthcoming) 525 Route 73 N. One Logan Square 12 | Marlton, New Jersey 08057 130 North 18" Street Philadelphia, PA 9103 13 | LAW OFFICE OF MAILK W. AHMAD 14 Malik W. Ahmad Andrew T. Hambelton NV Bar No. 10305 NY Bar No. 4835419 15 | 8465 West Sahara Ave., Suite 111 (pro hac vice forthcoming) Las Vegas, NV 89117 1271 Avenue of the Americas 16 New York, New York 10020 Attorneys for Plaintiffs 17 | and the Proposed Class Attorneys for CoxCom, LLC 18 19 ORDER 20 IT IS SO ORDERED:

22 ( So ANDREW P. GORDON 23 CHIEF UNITED STATES DISTRICT JUDGE 24 Dated: January 17, 2025 25 26 27 28