1 ROBERTA L. STEELE, SBN 188198 (CA) MARCIA L. MITCHELL, SBN 18122 (WA) 2 MARIKO M. ASHLEY, SBN 311897 (CA) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 3 San Francisco District Office 450 Golden Gate Ave., 5th Floor West 4 P.O. Box 36025 San Francisco, CA 94102 5 Telephone No. (650) 684-0943 Fax No. (415) 522-3425 6 [email protected] 7 Attorneys for Plaintiff EEOC 8 [Additional Counsel Listed on Signature Block] 9 10 UNITED STATES DISTRICT COURT

11 DISTRICT OF NEVADA 12 U.S. EQUAL EMPLOYMENT OPPORTUNITY Case No. 3:24-cv-00444-MMD-CLB 13 COMMISSION, ORDER GRANTING 14 Plaintiff, STIPULATED MOTION TO STAY DISCOVERY 15 v. 16 (THIRD REQUEST) ABC Phones of North Carolina, Inc. d/b/a Victra 17 18 Defendant. 19 /// 20 21 /// 22 /// 23 24 /// 25 /// 26 27 /// 1 Per ECF No. 25, ECF No. 30, and ECF No. 35, Plaintiff U.S. Equal Employment Opportunity 2 Commission (“EEOC”) and Defendant ABC Phones of North Carolina, Inc. d/b/a Victra (“Victra”) by 3 and through their counsel (together, the “Parties”), submit this stipulation and respectfully request an 4 order to stay discovery for a period of 30 days, for a third time. 5 As reflected in ECF No. 25, ECF No. 30 , and ECF No. 35, the Parties reached a tentative 6 agreement to resolve this matter on Tuesday, March 5, 2025, at the Early Neutral Evaluation before 7 Magistrate Judge Craig S. Denney. 8 The Parties appeared before Judge Craig S. Denney on May 9, 2025, for a status conference 9 regarding the March 5, 2025 Early Neutral Evaluation and the Parties’ progress with negotiating the 10 terms of an agreement. The Parties updated the Court and explained they need additional time to 11 continue those discussions. EEOC proposed another status conference in 30-days to provide time to 12 review the proposed agreement. Victra agreed with that request, and the Parties also agreed that a third 13 30-day stay of discovery would be appropriate to allow the Parties to focus on the negotiations. 14 The Parties will appear before Judge Craig S. Denney on June 13, 2025 to provide a further 15 update on their negotiations. 16 This is the Parties’ third stipulation to stay discovery. 17 Good cause exists to stay discovery. Gibson v. MGM Resorts International, No. 2:23-cv- 18 00140-MMD-DJA,

, at *3 (D. Nev. July 11, 2023); see also Little v. City of Seattle, 19

(9th Cir. 1988) (District courts have wide discretion in controlling discovery, and 20 rulings to stay discover will not be overturned unless there is a clear abuse of discretion). A stay will 21 promote judicial economy and efficiency by allowing the Parties to continue their discussions and 22 finalize a resolution in good faith without incurring undue burden or expense. 23 All current discovery deadlines, including the deadline to submit an ESI Protocol (which was 24 March 21, 2025), EEOC’s deadline to respond to ABC Phones written discovery, and the deadlines 25 contained in the Second Discovery Plan and Proposed Scheduling Order (ECF No. 18) be suspended 26 during the pendency of the discovery stay. If the Parties are unable to agree upon additional terms to 27 resolve this matter, they will file a Third Discovery Plan and Proposed Scheduling Order for the Court’s 1 The Parties submit this stipulation in good faith and not for the purpose of delay or prejudice 2 | to any party. 3 || Respectfully submitted, 4 | Dated: May 13, 2025 5 BY: _/s/ Marcia L. Mitchell 6 MARCIA L. MITCHELL 7 Assistant Regional Attorney MARCIA L. MITCHELL, SBN 18122 (WA) 8 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 9 San Francisco District Office 450 Golden Gate Ave., 5“ Floor West 10 | P.O. Box 36025 San Francisco, CA 94102 11 | Telephone No. (650) 684-0943 Fax No. (415) 522-3425 12 [email protected] 13 Attorneys for Plaintiff EEOC 14 | BY: _/s/Suzanne L. Martin 15 SUZANNE L. MARTIN Suzanne L. Martin 16 | Nevada Bar No. 8833 OGLETREE DEAKINS, NASH, SMOAK & STEWART, P.C. 17 | 10801 W. Charleston Blvd., Suite 500 Las Vegas, NV 89135 18 | Telephone: 702-369-6800 19 Fax: 702-369-6888 29 || Attorneys for Defendant, ABC Phones of North Carolina, Inc. d/b/a/ Victra 21 22 IT IS SO ORDERED. 23 UNITED STATES MAGISTRATE JUDGE 24 HON. C A BALDWIN 25 DATED: May 13, 2025 26 27 28