Tyler v. Golden Road Motor Inn, Inc.

1 THIERMAN BUCK SUTTON HAGUE LAW Joshua D. Buck, Nev. Bar No. 12187 CORPORATIONS, P.C.

2 || Leah L. Jones, Nev. Bar No. 13161 S. Brett Sutton, Nev. Bar No. 143107 W. Liberty Street Jared Hague, Nev. Bar No. 251517 || Reno, Nevada 89501 9790 Gateway Drive || Tel (775) 284-1500 Suite 4a 89521 eno, Nevada ran uP) a Telephone: (775) 284-2770 || [email protected] Fax No... (775) 313-9877 ‘ [email protected] brett(@suttonhague.com [email protected] Attorneys for Plaintiff and the Putative Classes Attorneys for Defendant 8 Golden road Motor, Inn., Inc. 10 UNITED STATES DISTRICT COURT ll DISTRICT OF NEVADA 2212 JEFFERSON TYLER, on behalf of himself Case No.: 3:24-CV-00565-MMD-CLB || and all others similarly situated ORDER GRANTING 14 . STIPULATION TO STAY Plaintiff, PROCEEDINGS AND [PROPOSED] 15 ORDER THEREON vs. (FIRST REQUEST) ce 7 GOLDEN ROAD MOTOR INN, INC. d/b/a = ATLANTIS CASINO RESORT SPA; and || DOES 1 through 50, inclusive, 19 Defendant(s).

Plaintiff JEFFERSON TYLER (“Plaintiff”) and Defendant GOLDEN ROAD MOTOR INN, INC. d/b/a ATLANTIS CASINO RESORT SPA; and DOES 1 through 50, inclusive, (“Defendant” or “Atlantis”) (collectively, the “Parties”), by and through their respective counsel of record, hereby agree and stipulate to stay the above captioned case up to and including August 7, 2025, pending a scheduled mediation with the Honorable Judge Amy Hogue (Ret.).

26 The purpose of this stipulation is to promote judicial economy and permit this Court to effectively control the disposition of cases on its docket with economy of time and effort for 2g itself, counsel, and the litigants. See Landis v. N. Am. Co., 299 U.S. 248, 254 (1936) (“[T]he -|- || power to stay proceedings is incidental to the power inherent in every court to control the || dispositions of the causes on its docket with economy of time and effort for itself, for counsel, || and for litigants.”); Pate v. DePay Orthopedics, Inc., No. 2:12-ev-01168-MMD-CWH, 2012 WL 4 3532780, *2 (D. Nev. Aug. 14, 2012) (“A trial court may, with propriety, find it is efficient for || its own docket and the fairest course for the parties to enter a stay of an action before it, pending resolution of independent proceedings which bear upon the case.”) (internal citations omitted).

In evaluating whether to stay proceedings, the Court considers the competing interests of the parties and of the Court, including “‘possible damage which may result in granting the stay, the ° hardship or inequity which a party may suffer in being required to go forward, and the orderly : course of justice measured in terms of simplifying or complicating of issues, proof, and questions 5 of law which could expected to result from a stay.’” Coker v. Dowd, No. 2:13-cv-0994-JCM- : 1B NJK, 2013 WL 12216682, *1 (D. Nev. Jul. 8, 2013) (granting joint motion to stay all proceedings pending mediation), quoting Lockyer v. Mirant Corp., 398 F.3d 1098, 1110 (9th Cir. 2005). = 5 15 The Parties have scheduled mediation with the Honorable Judge Amy Hogue (Ret.) for || August 7, 2025.

217 Based on the foregoing, the Parties agree that their interests are aligned in seeking to E 18 || potentially resolve the matter entirely without expending unnecessary litigation costs and efforts, ||and that neither Plaintiff nor Defendant will be prejudiced by a stay of the proceedings. The || Parties also agree that they will each suffer an avoidable hardship — time and money spent || litigating — if the matter is required to proceed at this stage considering the Parties’ agreement to || explore a potential resolution. Lastly, the Parties respectfully submit that staying all proceedings || will avoid the waste of judicial resources by simplifying or entirely disposing of the issues in this |! action. Accordingly, the Parties agree and stipulate that good cause exists to stay all proceedings as requested herein.

26 The Parties will file a joint status report informing the Court of the outcome of their efforts a to resolve Plaintiff’s claims within fourteen (14) days of the expiration of this stay, on or before August 21, 2024: _2- ] 1. Should the Parties reach a settlement of all claims, the Parties will update the || Court as to the tentative resolution and set forth a proposed briefing schedule for settlement || approval; or 4 2. Should the Parties be unsuccessful at resolving all claims, the Parties shall inform || the Court which, if any, claims were not resolved and propose a scheduling order for the matter to proceed, including an updated Discovery Plan and Scheduling Order.

This stipulation is submitted in good faith to allow the parties to potentially resolve the matter entirely and is not for the purpose of causing any undue delay. This is the first request to stay this case.

2 10 B a 5 11 || Dated: March 24, 2025 Dated: March 24, 2025 $212 THIERMAN BUCK SUTTON HAGUE LAW CORPORATIONS, 13 P.C.

3 14 || is/ Leah L. Jones /s/ Jared Hague = 3 4 15 Joshua D. Buck, Nev. Bar No. 12187 S. Brett Sutton, Nev. Bar No. 143107 Leah L. Jones, Nev. Bar No. 13161 Jared Hague, Nev. Bar No. 251517 || 325 W. Liberty Street 9790 Gateway Drive Reno, Nevada 89501 Suite 200 Reno, Nevada 89521 atone fo en Attorneys for Defendant ee GOLDEN ROAD MOTOR INN, INC. d/b/a ATLANTIS CASINO RESORT SPA IT ISSO ORDERED.

DATED: March 25, 2025 25 United States District Judge -3-