1 GRIFFITH H. HAYES 2 Nevada Bar No. 7374 NICHOLAS F. PSYK 3 Nevada Bar No. 15983 Email(s): [email protected] 4 [email protected] 2835 St. Rose Pkwy., Suite 140 5 Henderson, NV 89052 Telephone: (702) 724-2648 6 Facsimile: (702) 410-7684 Attorneys for Defendant Sam's West, Inc., 7 erroneously sued as Walmart Claims Services, Inc., d/b/a Sam's Club. 8

9 UNITED STATES DISTRICT COURT

10 DISTRICT OF NEVADA

11 HONG SOOK CHOI, an individual; Case No.: 2:24-cv-02095-RFB-BNW

12 Plaintiff, STIPULATION AND PROPOSED ORDER TO EXTEND DISCOVERY DEADLINES 13 v. (FIRST REQUEST) 14 WALMART CLAIMS SERVICES, INC. d/b/a SAM’S CLUB, LLC., a Foreign 15 Corporation; DOES 1 through 25, inclusive; and ROE CORPORATIONS 1 16 through 25, inclusive;

17 Defendants.

18 IT IS HEREBY STIPULATED AND AGREED, between the parties and their attorneys 19 of record, that the current discovery deadlines be extended pursuant to Local Rule 26-3. 20 I. DISCOVERY COMPLETED TO DATE 21 1. The parties have conducted the FRCP 26.1 Early Case Conference. 22 2. Plaintiff has produced her Lists of Witnesses and Documents pursuant to FRCP 23 26(a). 24 3. Defendant has produced its Lists of Witnesses and Documents pursuant to FRCP 25 26(a) 26 4. Defendant has propounded discovery to Plaintiff. 27 5. Plaintiff has propounded discovery to Defendant. 28 1 2 7. Plaintiff has produced her First Supplement to Rule 26 disclosure. 3 8. Plaintiff has produced her Second Supplement to Rule 26 disclosure. 4 II. DISCOVERY THAT REMAINS TO BE COMPLETED 5 1. Deposition of Plaintiff. 6 2. FRCP 35 Examination, tentatively scheduled for April 25, 2025. 7 3. Deposition of Defendant Walmart Inc.’s 30(b)(6) witness(es). 8 4. Disclosure of Initial Experts. 9 5. Disclosure of Rebuttal Experts. 10 6. Deposition(s) of Plaintiff’s treating physicians. 11 7. Deposition of other percipient witnesses. 12 8. Depositions of experts. 13 9. Issuing subpoenas to additional third-parties, including Plaintiff’s medical 14 providers (if any). 15 10. Additional written discovery (if necessary). 16 11. Any remaining discovery the parties deem relevant and necessary as discovery 17 continues. 18 III. 19 WHY DISCOVERY CANNOT BE COMPLETED WITHIN THE TIME PROVIDED BY 20 THE CURRENT SCHEDULING ORDER

21 LR 26-3 governs modifications or extension of the Discovery Plan and Scheduling Order. 22 Any stipulation or motion to extend or modify that Discovery Plan and Scheduling Order must 23 be made no later than twenty-one (21) days before the expiration of the subject deadline and 24 must comply fully with LR 26-3. If the stipulation is made less than twenty-one (21) days before 25 the expiration of a deadline, the parties must show a good cause exist. A request made after the 26 expiration of the subject deadline will not be granted unless the movant also demonstrates that 27 the failure to act was the result of excusable neglect. 28 A request to extend unexpired deadlines in the scheduling order must be premised on a 1 2 on whether the subject deadlines cannot reasonably be met despite the exercise of diligence. 3 Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). 4 The parties respectfully submit, pursuant to Local Rule 26-3, that good cause exists for 5 the following requested extension. This Request for an extension of time is not sought for any 6 improper purpose or other purpose of delay. Good cause for the extension is the parties have 7 agreed to proceed with Plaintiff’s Rule 35 Examination with defense expert Dr. Wang, but Dr. 8 Wang’s earliest availability to conduct the examination is April 25, 2025. Dr. Wang will also 9 require 30-days following the examination for preparation of his report. The parties have 10 tentatively agreed to set Plaintiff’s Rule 35 Examination with Dr. Wang for April 25, 2025, 11 pending the Court’s approval of the instant request. Based on the foregoing, both Plaintiff and 12 Defense counsel are requesting that the remaining scheduling order dates be extended by 60 13 days. 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 IV. PROPOSED SCHEDULUE FOR COMPLETING REMAINING DISCOVERY 3 Discovery Deadline Current Deadline Proposed Deadline 4 Motion to Amend/Add Parties March 17, 2025 March 17, 2025 Initial Expert Disclosures April 14, 2025 June 13, 2025 5 || All Rebuttal Expert Disclosures May 14, 2025 July 14, 2025 Discovery Cut-Off Date June 13, 2025 August 12, 2025 6 July 14, 2025 September 12, 2025 8 The parties represent this Stipulation is sought in good faith and not interposed for delay g |} or any other improper purpose. 10 IT IS SO STIPULATED. Dated this 11" day of April 2025 Dated this 11" day of April 2025 12 || TYSON & MENDES LLP KANG & ASSOCIATES, PLLC 13 /s/ Griffith H. Haves /s/ Adam Gill GRIFFITH H. HAYEs PATRICK W. KANG, Nevada Bar No. 7374 Nevada Bar No. 10381 15 NICHOLAS F. PSYK KYLE R. TATUM Nevada Bar No. 15983 Nevada Bar No. 13264 16 || 2835 St. Rose Pkwy., Suite 140 ADAM L. GILL Henderson, Nevada 89052 Nevada Bar No. 11575 17 || Attorneys for Defendant Sam's West, Inc. 1707 Village Center Circle, Suite 100 18 Las Vegas, Nevada 89135 Attorneys for Plaintiff 19 20 21 92 || IT ISSO ORDERED. 23 lea □□□ □□□ 24 ITED STATES MAGISTRATE JUDGE 25 . DATED this 4/14/2025 26 27 28

To: Nick Psyk; hcaifano acelawgroup.com Cc: Griffith Hayes; Heidi Brown; pkang acelawgroup.com; Mariana Gomez; scho acelawgroup.com Subject: Re: 2:24-cv-02095-RFB-BNW Choi vs Sam"s West, Inc. - SAO Regarding NRCP Rule 35 Exam of Plaintiff Date: Friday, April 11, 2025 12:45:07 PM Attachments: image001.png Hi Nick, Thank you for preparing. You can affix my e-signature. Take care, Adam L. Gill, Esq. Partner ACE LAW GROUP 6480 W. Spring Mountain Rd., Ste 1 Las Vegas, NV 89146 P: 702.333.4223 F: 702.507.1468 www.acelawgroup.com

NOTICE: If you have received this message in error, or are not the named or intended recipient(s), please immediately notify the sender at (702) 333-4223 and delete this E-mail message and any attachments from your workstation or network mail system. If you are a client or work for a client of ACE LAW GROUP or have consulted with the law firm for potential representation, this E-mail is protected by the attorney-client privilege and the work product doctrine. This E-mail is not intended for release to opposing parties, opposing counsel or any other third person or entity. Caution should be used when forwarding this E-mail to others within the company as the privilege may be lost. Copies of this E-mail should not be kept in your regular files. From: Nick Psyk <[email protected]> Sent: Friday, April 11, 2025 12:15 PM To: hcaifano acelawgroup.com <[email protected]> Cc: Griffith Hayes <[email protected]>; Heidi Brown <[email protected]>; Adam Gill <[email protected]>; pkang acelawgroup.com <[email protected]>; Mariana Gomez <[email protected]>; scho acelawgroup.com <[email protected]> Subject: RE: 2:24-cv-02095-RFB-BNW Choi vs Sam's West, Inc. - SAO Regarding NRCP Rule 35 Exam of Plaintiff

Ms. Caifano, Given we are in federal court, any reference to “NRCP 35” or “Nevada Rule of Civil Procedure 35 in the SAO should be replaced with “FRCP 35” or “Federal Rule of Civil Procedure 35” given the federal rules would apply. Also, paragraph 10 states “Defendant will bear the cost of the interpreter”. | understand you previously notified us an interpreter would be present during the exam, but! do not believe we previously discussed that Defendant would bear the cost of the interpreter. | have not had a situation before where the party requesting a Rule 35 Exam paid for the interpreter, so please let me Know if you can clarify who will be paying for the interpreter for this Exam. Finally, with regards to requesting a 60-day extension, | believe we will need to submit a separate SAO for the extension. | have attached a draft of that SAO for review and approval. Please let me know if your office approves the attached draft stipulation for submission to the Court today. Thank you, Nicholas Psyk Attorney 2835 St. Rose Pkwy., Suite 140 Henderson, NV 89052 Main: 702.724.2648 Direct: 725.235.7475 Fax: 702.410.7684 [email protected] www.tysonmendes.com

This email and any attachments are from the law firm of Tyson & Mendes, LLP. This email is intended only for the use of the addressee and may contain information that is proprietary, confidential, privileged, or protected by state or federal law. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this email and attachments are prohibited. If you received this email in error, please notify us by reply email immediately so we may arrange for the retrieval of the information. From: hcaifano acelawgroup.com <[email protected]> Sent: Friday, April 11, 2025 11:44 AM To: Nick Psyk <[email protected]> Ce: Griffith Hayes <[email protected]>; Heidi Brown <[email protected]>; Adam Gill <[email protected]>; pkang acelawgroup.com <[email protected]>; Mariana Gomez <[email protected]>; scho acelawgroup.com <[email protected]> Subject: Re: 2:24-cv-02095-RFB-BNW Choi vs Sam's West, Inc. - SAO Regarding NRCP Rule 35 Exam of Plaintiff Good morning Mr. Psyk, I am following up on the SAO Regarding NRCP 35 Exam. Initial Expert Disclosures are currently due Monday; however, the SAO contains a request to extend discovery by 60 days. Please track any changes you may have and kindly provide written permission to attach your electronic signature. Thank you and have a great rest of your day. Regards, Heather Caifano Paralegal Director ACE LAW GROUP 6480 W. Spring Mountain Rd., Ste 1 Las Vegas, NV 89146 P: 702.333.4ACE (223) F: 702.507.1468 www.acelawgroup.com

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