1 Laurent R.G. Badoux, Esq. Nevada Bar No. 07265 2 LITTLER MENDELSON, P.C. Camelback Esplanade 3 2425 East Camelback Road Suite 900 4 Phoenix, Arizona 85016 Telephone: 602.474.3600 5 Fax No.: 602.957.1801 [email protected] 6 Kelsey E. Stegall, Esq. 7 Nevada Bar No. 14279 LITTLER MENDELSON, P.C. 8 3960 Howard Hughes Parkway Suite 300 9 Las Vegas, Nevada 89169.5937 Telephone: 702.862.8800 10 Fax No.: 702.862.8811 [email protected] 11 Attorneys for Defendants 12 MARLOU CORP D/B/A CLUB PLATINUM AND RITA CAPOVILLA 13 UNITED STATES DISTRICT COURT 14 DISTRICT OF NEVADA 15 LINDA WHEELER and KARISSA ANN Case No. 2:23-cv-01556-APG-BNW 16 HUGH, individually, and on behalf of similarly situated individuals, STIPULATION AND ORDER TO 17 STAY DISCOVERY PENDING Plaintiffs, MEDIATION 18 v. [SECOND REQUEST] 19 MARLOU CORPORATION d/b/a CLUB 20 PLATINUM, a Nevada corporation, and RITA CAPOVILLA, 21 Defendants. 22 23 Plaintiffs LINDA WHEELER and KARISSA ANN HUGH, and Defendant MARLOU 24 CORPORATION d/b/a CLUB PLATINUM and RITA CAPOVILLA, through their respective 25 counsel, hereby stipulate and agree to stay discovery pending mediation. 26 Courts have “broad discretion in managing their dockets.” Byars v. Western Best, LLC, No. 27 2:19-cv-1690-JCM-DJA,

, at *1 (D. Nev. Jul. 6, 2020) (citing Clinton v. Jones, 520 28

, 706–07 (1997)). In exercising this discretion, “court are guided by the goals of securing the 2 just, speedy, and inexpensive resolution of actions.” Id.; see also Fed. R. Civ. P. 1. This broad 3 discretion applies to discovery, including whether to allow or deny discovery. See e.g., Little v. City 4 of Seattle,

(9th Cir. 1988). 5 The parties requested a 60-day stay of discovery in order to engage in third-party mediation, 6 which the Court granted and stayed discovery until May 19, 2025, (ECF No. 34). The parties scheduled 7 mediation with their agreed-upon mediator to occur on May 20, which was the only mutually agreeable 8 date of availability for the mediator and the parties’ counsel. Given that the parties have not yet 9 engaged in the mediation, the parties are requesting an additional 14-day stay of discovery to allow 10 for the mediation to occur and any other logistics to be figured out in that time. This would extend the 11 stay from May 19, 2025, to June 2, 2025. No later than June 2, 2025, the parties will file a joint status 12 report indicating whether settlement was reached or setting forth new proposed deadlines for the close 13 of discovery, dispositive motions, the pretrial conference, and trial. 14 Accordingly, the parties agree that good cause exists to continue the stay of discovery given 15 that the parties will imminently engage in formal mediation in an attempt to pursue a full resolution 16 of this matter. See Schrader v. Wynn Las Vegas, LLC, No. 2:19-cv-02159-JCM-BNW,

4810324, at *4 (D. Nev. Oct. 14, 2021); Aristocrat Techs., Inc. v. Light & Wonder, Inc., No. 2:24-cv- 18 00382-GMN-MDC,

, at *1 (D. Nev. May 21, 2024). 19 Therefore, the Parties hereby agree and stipulate that: 20 1. All discovery deadlines in this action shall continue to be stayed for an additional 21 period of fourteen (14) days in order for the parties to engage in mediation. The parties thus request 22 discovery be stayed until June 2, 2025, in order to facilitate mediation efforts and to divert time and 23 resources to same. 24 2. Should mediation result in resolution, the parties will notify the Court accordingly. 25 Should mediation not result in resolution, no later than June 2, 2025, the parties agree to submit a 26 stipulation setting forth new proposed deadlines for the close of discovery, dispositive motions, the 27 pretrial conference, and trial. 28 3. The parties represent that they would expect to request an additional sixty (60) days to 1 || complete discovery if mediation is not successful. 2 4. This 1s this second request for a limited stay of discovery and a second request related 3 | to scheduling order. 4 5. The parties agreed that pursuant to Local Rule 26-3, a motion or stipulation to extend 5 || adeadline set forth above must be received by the Court no later than 21 days before the expiration of 6 || the subject deadline, and a request made within 21 days of the deadline must be supported by a 7 || showing of good cause. 8 6. The Parties aver that good cause exists here because the parties have scheduled 9 | mediation, will participate in it shortly, and will update the Court accordingly regarding the results 10 | from the same. 11 7. The Parties make this stipulation in good faith and not for the purpose of delay. 12 | Dated: May 13, 2025 Dated: May 13, 2025 13 Respectfully submitted, Respectfully submitted, 14 /s/ Matthew Thomson /s/ Kelsey E. Stegall 15 Matthew Thomson Laurent R.G. Badoux Lichten & Liss-Riordan, PC Kelsey E. Stegall 16 Littler Mendelson Kristina L. Hillman 17 Sean W. McDonald Attorneys for Defendants Weinberg, Roger & Rosenfeld MARLOU CORP d/b/a CLUB PLATINUM 18 and RITA CAPOVILLA Attorneys for Plaintiffs 19 | LINDA WHEELER and KARISSA ANN HUGH

21 IT IS SO ORDERED. 22 23 ZK g_~— Las Use UNI STATES MAGISTRATE JUDGE □ 24 | Dated: May 16, 2025 25 26 27 28 NDELSON, P.C. Hughes Pkwy