1 NLEevWad Ba RBaArN NDoO. 5N8,8 J0R ., ESQ. 2 RYAN VENCI, ESQ. Nevada Bar No. 7547 3 KRISTEN MOLLOY, ESQ. 4 Nevada Bar No. 14927 BRANDON | SMERBER LAW FIRM 5 139 E. Warm Springs Road Las Vegas, Nevada 89119 6 (702)380-0007 7 (702)380-2964 – facsimile [email protected] 8 [email protected] [email protected] 9 Attorneys for Defendant, 10 ALBERTSON’S, LLC. 11 UNITED STATES DISTRICT COURT STATE OF NEVADA 12 13 MARIETTA VALLEN, an individual, CASE NO.: 2:24-cv-2155-RFB-EJY 14 Plaintiff, STIPULATED AND ORDER TO EXTEND DISCOVERY DEADLINES 15 vs. (FIRST REQUEST) 16 ALBERTSON’S LLC., a Foreign Limited- 17 Liability Company; CHRISTENSEN DEVELOPMENT, LP, a Foreign Limited 18 Partnership; TRAILS VILLAGE CENTER 19 COMPANY, an unregistered Domestic Corporation dba TRAILS VILLAGE 20 CENTER; DOES 1-20 and ROE BUSINESS ENTITES 1-20, inclusive, 21 Defendants. 22 23 Pursuant to Local Rules 26-3, the parties respectfully submit the following stipulation to 24 extend the discovery deadlines in this matter by ninety (90) days. 25 A. A Statement Specifying the Discovery Completed (LR 26-3(a): 26 1. Plaintiff has made her initial disclosures pursuant to Fed. R. Civ. P. 26(a); 27 2. Defendant Albertson’s LLC have made their initial disclosures and supplemental 28 disclosures pursuant to Fed. R. Civ. P. 26(a); 1 3. Defendants Christensen Development, LP and Trails Village Center Company 2 have made their initial disclosures and supplemental disclosures pursuant to Fed. 3 R.Civ. P. 26(a); 4 4. Defendant Albertson’s LLC has served written discovery on Plaintiff; 5 5. Defendants Christensen Development, LP and Trails Village Center Company 6 have served written discovery on Plaintiff; Plaintiff has responded to Defendant 7 Albertson’s LLC’s written discovery; 8 7. Plaintiff has responded to Defendants Christensen Development, LP and Trails 9 Village Center Company’s written discovery; 10 8. Plaintiff has served written discovery to Defendant Albertson’s LLC; 11 9. Plaintiff has served written discovery to Defendants Christensen Development, 12 LP and Trails Village Center Company; 13 10. Defendants Christensen Development, LP and Trails Village Center Company 14 have responded to Plaintiff’s written discovery; 15 11. Plaintiff has served written discovery to Defendant Albertson’s LLC; and 16 12. Defendant Albertson’s LLC has responded to Plaintiff’s written discovery. 17 B. A Specific Description of the Discovery that Remains to be Completed (LR 18 26-3(b): 19 1. Plaintiff’s deposition (currently scheduled for March 5, 2025); 20 2. The deposition(s) of Albertson’s LLC’s employee(s) Stephen Yoli and Jennifer Fargnoli; 21 3. The deposition of Defendants’ Rule 30(b)(6) witness(es); 22 4. Rule 34 Site Inspection of Defendants’ premises; 23 5.. Disclosure of expert witnesses and rebuttal expert witnesses; 24 6. Expert and treating physician depositions; and 25 7. Deposition Duces Tecum of the two contractors that performed maintenance of 26 the parking. 27 28 1 C. The Reasons why the Deadline was not Satisfied or the Remaining 2 Discovery was not Completed within the Time Limits set by the Discovery 3 Plan (LR 26-3(c): 4 Following removal, the parties litigated the potential for removal. The parties diligently 5 conducted discovery while this motion was pending, but due to that delay along with counsel’s 6 schedules, depositions currently cannot be scheduled in time to meet the current initial expert 7 disclosure deadline. In addition, Plaintiff needs to conduct additional discovery as to the location 8 where the subject incident took place and the responsibility among the Defendants for the area 9 where the subject incident took place, including employee and Rule 30(b)(6) depositions and a 10 site inspection, before she will be able to designate an expert on liability. The parties believe that 11 good cause exists to extend the discovery deadlines in this matter as they have been working 12 diligently in the discovery process and have not delayed it with the exception of being unable to 13 schedule depositions. Further, all of the discovery dates the parties wish to extend are more than 14 twenty-one (21) days from the submission of this Stipulation and Order. 15 D. A Proposed Schedule for Completing all Remaining Discovery (LR 26- 16 3(d): 17 Current Deadlines: Proposed Deadline: 18 Amend Pleadings: February 18, 2025 Closed 19 Initial Expert Disclosure: March 20, 2025 June 16, 2025 20 Rebuttal Expert Disclosure: April 18, 2025 July 16, 2025 21 Discovery Cut-off: May 19, 2025 August 15, 2025 22 … 23 … 24 … 25 … 26 … 27 … 28 … Dispositive Motions: June 18, 2025 September 12, 2025 Joint Pre-Trial Order: July 18, 2025 October 11, 2025 4 DATED this 13" day of February, 2025. DATED this 13" day of February, 2025.

5 BRANDON | SMERBER LAW FIRM MORGAN & MORGAN 6 /s/ Ryan Venci, Esq. /s/ Gregory Kraemer, Esq. 7 LEW BRANDON, JR., ESQ. GREGORY KRAEMER. ESQ. Nevada Bar No. 5880 Nevada Bar No. 10911 RYAN M. VENCTI, ESQ.

" Street, Suite 500 9 Nevada Bar No. 7547 Las Vegas, Nevada 89101 KRISTEN MOLLOY, ESQ. Attorneys for Plaintiff, 10 || Nevada Bar No. 14927 MARIETTA VALLEN i 139 E. Warm Springs Road Las Vegas, Nevada 89119 12 Attorneys for Defendant, ALBERTSON'S LLC 13 4 DATED this 13" day of February, 2025 15 OLSON CANNON & GORMLEY 16 || /s/ Stephanie Zinna, Esq. M STEPHANIE ZINNA, ESQ. ig || Nevada Bar No. 11488 9950 West Cheyenne Avenue 19 Las Vegas, Nevada 89129 Attorneys for Defendants, °0 || CHRISTENSEN DEVELOPMENT, LP and 1 TRAILS VILLAGE CENTER COMPNAY dba TRAILS VILLAGE CENTER 22 ORDER 23 — 24 IT ISSO ORDERED 25 DATED this 13th day of February, 2025. 26 Cana) |. AcucWol UNITED STA ES ‘AAGISTRATE JUDG 27 HONORABLE ELAYNA J. YOUCHAH 28