1 |} MARK J. BOURASSA, ESQ. (NBN 7999) JENNIFER A. FORNETTI, ESQ. (NBN 7644) 2 || VALERIE S. GRAY, ESQ. (NBN 14716) 3 || THE BOURASSA LAW GROUP 2350 W. Charleston Blvd., Suite 100 4 || Las Vegas, Nevada 89102 Telephone: (702) 851-2180 > Facsimile: (702) 851-2189 6 || Email: [email protected] [email protected] 7 [email protected] 8 NICHOLAS A. COLELLA (pro hac vice) 9 || LYNCH CARPENTER LLP 1133 Penn Avenue, 5“ Floor 10 || Pittsburgh, Pennsylvania 15222 1 Telephone: (412) 322-9243 Email: [email protected] 12 [Additional Counsel in Signature Block] 13 14 Attorneys for Plaintiffs 15 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA

17 || IN RE HANKINS PLASTIC SURGERY Case No.: 2:23-cv-00824-RFB-DJA ASSOCIATES, P. C. dba HANKINS & SOHN 18 || PLASTIC SURGERY ASSOCIATES STIPULATION AND ORDER TO MODIFY THE SCHEDULING ORDER 19 |! This Document Relates to: All Actions DEADLINES FOR PHASE I (PRE- 20 CERTIFICATION) OF DISCOVERY 21 (SECOND REQUEST) 22 23 Defendant Hankins & Sohn Plastic Surgery Associates, P.C. dba Hankins & Sohn Plastic 24 Surgery Associates (“Defendant”) by and through its counsel of record, SCHNITZER JOHNSON 25 ||& WATSON, CHTD., Plaintiffs Jennifer Tausinga, Alysia Wrenn, and Caroline Aurora 26 || (collectively “Plaintiffs”) on behalf of themselves and all other similarly situated, by and through 27 ||co-interim counsel of record, Jennifer A. Fornetti of The Bourassa Law Group and Nicholas A. 28 Colella of Lynch Carpenter LLP and Plaintiffs’ steering committee, Raina Borrelli of Strauss

1 Borrelli PLLC, Ramzy Ladah of Ladah Law Firm, and additional Plaintiffs’ counsel Clark 2 Seegmiller and Jonathan B. Lee of Richard Harris Law Firm, hereby stipulate to continue the 3 discovery deadlines and submit their Stipulation and Order to Modify the Scheduling Order 4 Deadlines for Phase I (Pre-Certification) of Discovery pursuant to Local Rule 26-3, as follows: 5 I. DISCOVERY COMPLETED AND ONGOING 6 1. On January 16, 2024, Plaintiffs, Jennifer Tausinga, Alysia Wrenn, and Olga 7 Romashova served their Initial Disclosure of Documents and Witnesses Pursuant to FRCP 8 26(a)(1). 9 2. On January 16, 2024, Plaintiffs, Jennifer Tausinga, Alysia Wrenn, and Olga 10 Romashova served their First Set of Interrogatories, First Set of Requests for Production of 11 Documents and Things, and First Request for Admissions to Defendant. Defendant served its 12 responses to this propounded discovery on March 12, 2024. Defendant subsequently served its 13 supplemental responses to Plaintiffs’ First Request for Admissions on November 5, 2024. 14 3. After the Court heard Defendant’s Motion to Stay Discovery or Alternatively, to 15 Bifurcate Discovery on April 9, 2024, Defendant Hankins Plastic Surgery Associates, P.C. served 16 its Initial FRCP 26 List of Witnesses and Production of Documents on April 29, 2024. 17 4. On July 12, 2024, Plaintiffs, Jennifer Tausinga, Alysia Wrenn, and Olga 18 Romashova served their Second Set of Interrogatories and Second Set of Requests for Production 19 of Documents and Things to Defendant. Defendant responded to this propounded discovery on 20 August 26, 2024, and supplemented its responses on October 5, 2024. 21 5. On July 29, 2024, Defendant Hankins Plastic Surgery Associates, P.C. served its 22 First Supplemental List of Witnesses and Production of Documents Pursuant to FRCP 26 List of 23 Witnesses and Production of Documents. 24 6. On October 10, 2024, Defendant Hankins Plastic Surgery Associates, P.C. served 25 its Second Supplemental List of Witnesses and Production of Documents Pursuant to FRCP 26 26 List of Witnesses and Production of Documents. 27 28 1 7. On November 5, 2024, Defendant Hankins Plastic Surgery Associates, P.C. served 2 its Third Supplemental List of Witnesses and Production of Documents Pursuant to FRCP 26 List 3 of Witnesses and Production of Documents. 4 8. On November 15, 2024, McBride Hall filed their Notice of Association of Counsel. 5 9. On January 7, 2025, Defendant Hankins Plastic Surgery Associates, P.C. served its 6 First Supplemental Responses to Plaintiffs’ First Set of Interrogatories and Requests for 7 Production of Documents and its Second Supplemental Responses to Plaintiffs’ Second Set of 8 Interrogatories and Requests for Production of Documents. 9 10. On January 7, 2025, Defendant Hankins Plastic Surgery Associates, P.C. served its 10 Fourth Supplemental List of Witnesses and Production of Documents Pursuant to FRCP 26 List 11 of Witnesses and Production of Documents. 12 11. On January 17, 2025, Defendant Hankins Plastic Surgery Associates, P.C. served 13 its First Set of Interrogatories to Plaintiffs. Plaintiffs will respond to these interrogatories on March 14 4, 2025. 15 12. On January 25, 2025, Plaintiffs served a subpoena on Amon Ra Network 16 Consulting. After attempting to meet and confer on the scope of the subpoenas pursuant to this 17 Court’s Order, Defendant filed its Motion for Protective Order on February 6, 2025. The Court is 18 set to hear Defendant’s Motion for Protective Order on March 18, 2025. Amon Ra produced 19 documents on February 25, 2025, and Plaintiffs are continuing to meet and confer with Amon Ra 20 regarding its production. 21 13. On January 26, 2025, Plaintiffs served a subpoena on I.T. Decisions. After 22 attempting to meet and confer on the scope of the subpoenas pursuant to this Court’s Order, 23 Defendant filed its Motion for Protective Order on February 6, 2025. The Court is set to hear 24 Defendant’s Motion for Protective Order on March 18, 2025. I.T. Decisions objected to 25 responding and Plaintiffs are continuing their efforts to enforce the subpoena. 26 14. On February 6, 2025, Plaintiffs served a Notice for a Rule 30(b)(6) deposition on 27 Defendant Hankins Plastic Surgery Associates, P.C. The parties are continuing to meet and confer 28 on the topics and scheduling. 1 15. On February 12, 2025, Defendant Hankins Plastic Surgery Associates, P.C. served 2 its First Set of Requests for Admission and Requests for Production of Documents on Plaintiffs. 3 Plaintiffs will respond to these requests on March 14, 2025. 4 16. On February 24, 2025, Defendant Hankins Plastic Surgery Associates, P.C. served 5 its Fifth Supplemental List of Witnesses and Production of Documents Pursuant to FRCP 26 List 6 of Witnesses and Production of Documents. 7 17. On January 23, 2025, Plaintiffs provided notice to Defendant that they intended to 8 serve a subpoena on Patient Now. After attempting to meet and confer on the scope of the 9 subpoenas pursuant to this Court’s Order, Defendant filed its Motion for Protective Order on 10 February 6, 2025. Plaintiffs successfully served their subpoena on Patient Now on February 26, 11 2025. The Court is set to hear Defendant’s Motion for Protective Order on March 18, 2025. 12 18. The parties are continuing to meet and confer on Defendant’s discovery responses 13 and production of documents in the hopes of avoiding Court intervention. 14 II. PENDING MOTIONS AND DISCOVERY THAT REMAINS TO BE 15 COMPLETED 16 On December 23, 2024, this Court granted Plaintiffs leave to file their Second Amended 17 Complaint. Dkt. 74. On December 30, 2024, Plaintiffs filed their Second Amended Complaint. 18 Dkt. 75. On January 13, 2025, Defendant moved to dismiss the Second Amended Complaint. Dkt. 19 76. Plaintiffs opposed that motion on January 24, 2025, Dkt. 77, and Defendant filed a reply, Dkt. 20 78. That motion remains pending. 21 On February 6, 2025, Defendant filed a motion for a protective order regarding the three 22 subpoenas Plaintiffs served on third parties. Dkt. 79. At its heart, this motion concerns the proper 23 scope of Phase I discovery set out in the initial Scheduling Order, Dkt. 48, which the parties have 24 differing interpretations of. 25 Due to the pending motion to dismiss and the pending motion regarding the subpoenas and 26 scope of discovery, the parties request that discovery be continued to allow all the parties to 27 continue to conduct Phase I discovery focused on information necessary for Plaintiffs’ motion for 28 class certification, including the “commonality, predominance, and typicality as it relates to 1 Plaintiffs and [the] putative class members.” “[W]hile discovery of certification issues during 2 Phase I may overlap with issues related to the merits in Phase II, the parties agreed to limit their 3 discovery in each Phase to the particular aims and subject matter of each respective Phase.” ECF 4 No. 48 at 4-5 (citing Tyus v. Wendy's of Las Vegas, Inc. , No. 214CV00729GMNVCF,

3026403, at *5 (D. Nev. July 17, 2017)). To that end, the Parties intend to conduct additional 6 written discovery, request and produce documents, and depositions. 7 As a result of these depositions, written responses, and document production, the parties 8 may decide to retain experts, which will result in the need for the experts to create reports and 9 potentially be deposed. Pursuant to Local Rule 1-1, the parties desire to do so in a cost-efficient 10 manner and with the Court’s goal of limiting and phasing discovery. 11 III. REASONS WHY THE REMAINING DISCOVERY CANNOT BE 12 COMPLETED WITHIN THE TIME LIMIT OF THE EXISTING 13 DEADLINE 14 Due to the pending motion to dismiss and the parties’ fundamental disagreement as to the 15 appropriate scope of Phase I discovery which is also currently pending before the Court, the parties 16 have been unable to complete discovery within the existing timeline. Additionally, Plaintiffs’ 17 Second Amended Complaint added another Plaintiff, Sarah Jefferson, and new counsel was 18 associated to represent Hankins & Sohn in this case from McBride Hall, see Dkt. 73. 19 As a result, the parties intend to conduct discovery in an efficient manner across the five 20 (5) other lawsuits filed against Hankins & Sohn to the fullest extent possible. As the motion to 21 dismiss and motion for a protective order are pending before the Court, the parties have shown 22 good cause and excusable neglect with this request pursuant to LR 26-3. See Bateman v. U.S. 23 Postal Serv.,

(9th Cir. 2000). 24 IV. PROPOSED SCHEDULE FOR COMPLETION OF PHASE I DISCOVERY 25 Based on the foregoing, the parties hereby stipulate and agree that an additional 90 days 26 are needed to complete Phase I discovery, and thus request that the following scheduling deadlines 27 be substituted for the deadlines contained in the Amended Scheduling Order: 28 1 Event Date 2 Interim Fact Discovery Cut-Off Date June 12, 2025 Close of Class Certification Expert Discovery July 16, 2025 3 Phase I (Pre-Certification) Discovery Cut-Off Date October 14, 2025 4 Amending Pleadings and Adding Parties June 12, 2025 5 Initial Class Certification Expert Designations July 16, 2025 6 Rebuttal Class Certification Expert Designations August 14, 2025 Motion for Class Certification October 14, 2025 7 Motions to Exclude Certification Experts November 17, 2025 Deadline to Participate in Mediation November 24, 2025 8 Joint Proposed Discovery Plan Regarding Post- Within 30 days of the Decision on 9 Certification Phase Motion for Class Certification

10 IT IS SO STIPULATED. 11 12 Dated: March 5, 2025 Dated: March 5, 2025 13 /s/ Brittany Resch /s/ Renee Green 14 Raina C. Borrelli (pro hac vice) L. Renee Green, Esq. (NBN 12755) Brittany Resch (pro hac vice) Gary E. Schnitzer, Esq. (NBN 395) 15 STRAUSS BORRELLI PLLC SCHNITZER JOHNSON & WATSON, CTD 16 980 N. Michigan Avenue, Suite 1610 8985 S. Eastern Ave., Ste. 200 Chicago, IL 60611 Las Vegas, NV 89123 17 Telephone: (872) 263-1100 Facsimile: (872) 263-1109 Robert C. Mcbride, Esq. (NBN 7082) 18 [email protected] Chelsea R. Hueth, Esq. (NBN 10904) 19 [email protected] 8329 W. Sunset Road, Suite 260 Las Vegas, Nevada 89113 20 Mark J. Bourassa, Esq. (NBN 7999) Jennifer A. Fornetti, Esq. (NBN 7644) Attorneys for Defendant 21 Valerie S. Gray, Esq. (NBN 14716) 22 THE BOURASSA LAW GROUP 2350 W Charleston Blvd, Suite 100 23 Las Vegas, Nevada 89102 [email protected] 24 [email protected] 25 [email protected] 26 27 28 1 || 4s/Nicholas A. Colella Nicholas A. Colella (pro hac vice) 2 |! 1133 Penn Avenue, 5" Floor 3 || Pittsburgh, PA 15222 4 || Attorneys for Plaintiff Tausinga 5 6 || Daniel C. Tetreault Daniel C. Tetreault, Esq. (NBN 11473) 7 || Ramzy P. Ladah (NBN 11405) g 517 S. Third Street Las Vegas, NV 89101 9 Attorneys for Plaintiff Wrenn 10 11 /s/ Jonathan Lee 12 || Jonathan B. Lee, Esq. (NBN 13524) Clark Seegmiller, Esq. (NBN 3873) 13 || 801 South Fourth Street 14 Las Vegas, NV 89101 15 || Attorneys for Plaintiff Caroline Aurora 16 17 18 19 IT IS SO ORDERED:

20 21 3/6/2025 22 |! Dated UNITED STATES MAGISTRATE JUDGE 23 24 25 26 27 28

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