THOMAS E. MCGRATH, ESQ. 1 Nevada Bar No. 7086 2 THANE A. WILLIAMS, ESQ. Nevada Bar No. 15991 3 LITCHFIELD CAVO LLP 3993 Howard Hughes Parkway, Suite 100 4 Las Vegas, Nevada 89169 Telephone: (702) 949-3100 5 Facsimile: (702) 916-1776 6 Email: [email protected] Email: [email protected] 7 Attorneys for Defendant Think 360, Inc. 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 MICHAEL GIRARD YACCINO, CASE NO.: 2:25-cv-00509-CDS-DJA 12 Plaintiff JOINT STIPULATION AND ORDER TO REMAND 13 v. 14 MANADALAY BAY LLC dba MANDALAY [ECF No. 3] BAY RESORT & CASINO, SHOPTALK 15 COMMERCE, LLC, THINK 360, INC., 16 Defendants 17 18 Pursuant to

(c), Plaintiff Michael Girard Yaccino (“Yaccino”) and 19 Defendant Think 360, Inc. (“Think 360”), by and through undersigned counsel, hereby jointly stipulate 20 to the remand of the above-captioned case, which was removed from the Eighth Judicial District Court 21 in Clark County, Nevada, to the United States District Court for the District of Nevada, on March 18, 22 2025, and in support thereof respectfully states as follows: 23 1. On February 20, 2025, Plaintiff filed the present lawsuit in the Eighth Judicial District Court 24 in Clark County, Nevada. 25 2. On March 18, 2025, Defendant Think 360 filed a petition to remove the present lawsuit to 26 federal court. 27 3. The parties, including Think 360, are in agreement that removal of the present lawsuit to 1 domiciled in Nevada. See

(b)(2) (“A civil action otherwise removable solely on the 2 basis of the jurisdiction under section 1332(a) of this title may not be removed if any of the parties in 3 interest properly joined and served as defendants is a citizen of the State in which such action is 4 brought.’). 5 4. Therefore, the present lawsuit should be remanded for lack of subject matter jurisdiction. 6 5. Defendants Mandalay Bay LLC dba Mandalay Bay Resort & Casino and Shoptalk Commerce, 7 LLC, have not yet appeared. 8 9 WHEREFORE, Defendants jointly stipulate that good cause exists to remand the present lawsuit to 10 the Eighth Judicial District Court in Clark County, Nevada. This stipulation is without prejudice to the 11 rights, claims, defenses, and arguments of the parties. 12 13 RESPECTFULLY SUBMITTED THIS DATE, the 24th day of March, 2025 14 15 DATED: March 24, 2025 LITCHFIELD CAVO LLP 16 By: /s/ Thomas E. McGrath 17 THOMAS E. MCGRATH, ESQ. Nevada Bar No. 7086 18 THANE A. WILLIAMS, ESQ. Nevada Bar No. 15991 19 LITCHFIELD CAVO LLP 3993 Howard Hughes Parkway, Suite 100 20 Las Vegas, Nevada 89169 21 Attorneys for Defendants Think 360 Inc. 22 /// 23 24 25 26 /// 27 1 || DATED: March 24, 2025 VALIENTE MOTT, LTD. 2 By: /s/ Peter Petersen 3 PETER PETERSEN, ESQ. Nevada Bar No. 14256 4 TIMOTHY ANDREW MOTT, ESQ. Nevada Bar No. 12828 5 VALIENTE MOTT, LTD. 6

" Street Las Vegas, Nevada 89101 7 Attorneys for Plaintiff 8 9 ORDER 10 Based on parties’ stipulation, which establishes that this court lacks subject- 11 || matter jurisdiction over this dispute, IT IS HEREBY ORDERED that the Clerk of 12 || Court is kindly directed to REMAND this case to the Eighth Judicial District Court, 13 || Department 21, Case No. A-25-913085-C, and to Close case. 14 Dated: March 25, 2025 Lf 15 Cristi . oiiva 16 unit States District Judge 17 ‘

18 19 || RESPECTFULLY SUBMITTED BY 20 || LITCHFIELD CAVO LLP 21 By: /s/ Thomas E. McGrath 22 THOMAS E. MCGRATH, ESQ. Nevada Bar No. 7086 23 THANE A. WILLIAMS, ESQ. Nevada Bar No. 15991 24 LITCHFIELD CAVO LLP 25 3993 Howard Hughes Parkway, Suite 100 Las Vegas, Nevada 89169 26 Attorneys for Defendants Think 360 Inc. 27 28