1]] KIMBALL JONES, ESQ. Nevada Bar No.: 12982 2!| BIGHORN LAW 3 3675 W. Cheyenne Ave., Suite 100 North Las Vegas, Nevada 89032 4|| Phone: (702) 333-1111 Email: [email protected] 5|| Attorneys for Plaintiffs 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 BABYSTACKS CAFE, LLC, a Domestic Limited | CASE NO.: 2:24-cv-01098-JCM-MDC ? Liability Company; REBEL KITCHEN INC. dba 109|| MANIZZA’S PIZZA, a Foreign Limited Liability Company; TIMELESS CUISINE, LLC dba 11} }ESTHER’S KITCHEN, a Domestic Limited STIPULATION AND PROPOSED Liability Company; GAETANO'S HOSPITALITY ORDER TO EXTEND TIME TO { GROUP, LLC dba GAETANO'S RISTORANTE, a RESPOND TO DEFENDANTS’ 4 13 Domestic Limited Liability Company; MUNCH-A- MOTION TO DISMISS SUB LLC, a Domestic Limited Liability Company, PLAINTIFFS’ SECOND AMENDED 0 14|| and on behalf of the Class of similarly situated COMPLAINT T individuals, (5 15 (FIRST REQUEST) m 16 Plaintiffs, vs. 18 UBER TECHNOLOGIES, INC., a Foreign 19|| Corporation; RASIER, LLC, a Foreign Limited Liability Company; BERCHMANN MELANCON, an individual; NICK “DOE”, an _ individual; 1 KARINA “DOE”, an individual; DOE CEO, I through X; DOE SALES REPRESENTATIVE, I through X; DOE MANAGER, I through X; DOE DRIVER, I through X; DOE EMPLOYEE, I 23||through X; DOES I through X; ROE CORPORATIONS, XI through XX; and ROE ENTITIES, XI through XX, inclusive, 2 Defendants. 26 Plaintiffs BABYSTACKS CAFE, LLC, a Domestic Limited Liability Company; REBEL 27 38 KITCHEN INC. dba MANIZZA’S PIZZA, a Foreign Limited Liability Company; TIMELESS

CUISINE, LLC dba ESTHER’S KITCHEN, a Domestic Limited Liability Company; GAETANO'S HOSPITALITY GROUP, LLC dba GAETANO'S RISTORANTE, a Domestic 3 Limited Liability Company; MUNCH-A-SUB LLC, a Domestic Limited Liability Company, and on behalf of the Class of similarly situated individuals, (hereinafter “Plaintiffs”) by and through 6 their counsel of record, KIMBALL JONES, ESQ., with BIGHORN LAW, and DEFENDANTS 7|| UBER TECHNOLOGIES, INC. RASIER, LLC and BERCHMANN MELANCON (hereinafter “Defendants”), by and through their counsel of record, of the law firm BROWNSTEIN HYATT 9 FARBER SCHRECK, LLP, and the law firm JENNER & BLOCK LLP, and hereby stipulate, contingent on this Court’s approval, as follows: > 1. On June 20, 2025, Plaintiffs filed their Second Amended Complaint. ECF 40. 5 13 2. On July 21, 2025, Defendants filed their Motion to Dismiss Plaintiffs’ Second 14 Amended Complaint. 0 15 3. The current date for Plaintiff to respond to the Motion is August 4, 2025. 0 16 4. Pursuant to LR JA 6-1(a), the Parties stipulate and agree that Plaintiff shall have an additional 21 days, up to and including August 25, 2025, to respond to the Motion to Dismiss Plaintiffs’ Second Amended Complaint. Defendants shall have

20 an additional 14 days, up to and including September 15, 2025, for their Response 21 to Plaintiffs’ Opposition. 22 5. There is a strong public policy in the Ninth Circuit of deciding cases on the merits, 23 rather than technicalities. See U.S. v. Signed Personal Check No. 730 of Yubran S. Mesle,

(9th Cir. 2010).

27||--- 28}]...

1 6. The is the Parties’ first request for an extension of time to respond to the Motion 2 to Dismiss Plaintiffs’ Second Amended Complaint. 3 4 5 6 DATED this Ist_ day of August, 2025. DATED this Ist_ day of August, 2025. 7 BIGHORN LAW BROWNSTEIN HYATT FARBER SCHRECK, LLP 8|| By:_/s/ Kimball Jones By: /s/ Remi Jaffre KIMBALL JONES, ESQ. KIRK B. LENHARD, ESQ. 3675 W. Cheyenne Ave., Suite 100 MAXIMILIEN D. FETAZ, ESQ. 10 North Las Vegas, NV 89032 JAMIE P. LEAVITT, ESQ. Email: [email protected] 11 JENNER & BLOCK LLP 2 Attorneys for Plaintiffs KATE SPELMAN, ESQ. 12 (pro hac vice) | 4 3 REMI JAFFRE, ESQ. (pro hac vice) O 14 T Attorneys for Defendants Uber Technologies, (5 15 Inc.; Rasier, LLC; and Berchmann Melancon o 16 17|| IT IS SO ORDERED. 18 c < 19 RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE 20 DATED: _ This 3rd day of August, 2025.

22 23 24 25 26 27 28

Gma | | Amy Cvetovich <[email protected]:>

[External] RE: Babystacks, et al. v. Uber, et al. message Remi J.D. <[email protected]> Fri, Aug 1, 2025 at 3:16 PM Amy Cvetovich <[email protected]> "Spelman, Kate T." <[email protected]>, "Kimball Jones, Esq." <[email protected]>, Emily Grable

Thanks, Amy, this looks good to file.

From: Amy Cvetovich <[email protected]> Sent: Friday, August 1, 2025 5:40:00 PM To: Jaffre, Remi J.D. <[email protected]> Cc: Spelman, Kate T. <[email protected]>; Kimball Jones, Esq. <[email protected]>; Emily Grable <[email protected]> Subject: Re: [External] RE: Babystacks, et al. v. Uber, et al.

External Email - Do Not Click Links or Attachments Unless You Know They Are Safe Hi Remi, Please see attached Stipulation and let me know if | may affix your e-signature. Thanks again! Amy Cvetovich = Lead Litigation Manager

BIGHORN 7 Tel: = 702-333-1111 Ext. 161 LAW d vs Email: [email protected] all Web: bighorniaw.com

° Cae sae. LAS VEGA Ane iy

This email and any attachments are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please contact the sender(s) at (702) 333-1111 and delete all copies from your system. Please note that any opinions in this email are solely those of the author and do not necessarily represent those of Bighorn Law, and is not to be considered legal advice.

On Fri, Aug 1, 2025 at 2:36 PM Amy Cvetovich <[email protected]> wrote: Yes, of course! Thank you! | will send the Stip over in just a few minutes.

Amy Cvetovich >: Lead Litigation Manager □ ot BIGHORN Tel: 702-333-1111 Ext. 161 LAV PS Email: [email protected] > say «=—« Web: bighornlaw.com

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On Fri, Aug 1, 2025 at 9:37AM Jaffre, Remi J.D. <[email protected]> wrote: Hi Amy,

We will agree to your proposal, as long as the stipulation also extends our time to file a reply brief by two weeks (putting our respective deadlines at August 25 and September 15). Please let me know if that works.

Relately, | want to reiterate that we are prepared to make a modest payment to settle this matter—but it would have to be much closer to our latest offer than your latest counterproposal. | will connect with Kimball separately about that.

Thanks,

Remi

Rémi J.D. Jaffré Jenner & Block LLP 1155 Avenue of the Americas New York, NY 10036-2711 | jenner.com +1 212 303 2536 | Tel +1 312 859 1921 | Mobile Pronouns : He / Him [email protected] Download V-Card | View Biography CONFIDENTIALITY WARNING: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). Any unauthorized use or disclosure of this communication is prohibited. If you believe that you have received this email in error, please notify the sender immediately and delete it from your system

From: Amy Cvetovich <[email protected]> Sent: Friday, August 1, 2025 11:55 AM To: Jaffre, Remi J.D. <[email protected]>; Spelman, Kate T. <[email protected]> Cc: Kimball Jones, Esq. <[email protected]>; Emily Grable <[email protected]> Subject: Babystacks, et al. v. Uber, et al.

External Email - Do Not Click Links or Attachments Unless You Know They Are Safe Good Morning Remi,

| hope you're doing well and having a great week so far!

We have our Opposition to your Motion to Dismiss due on Monday. Kimball is in trial in California currently. May we please have a three week extension for our opposition, making it due August 25th? If approved, I'll send a Stipulation over. Thanks!

Amy Cvetovich

aa Lead Litigation Manager

BIGHORN Tel: 702-333-1111 Ext. 161 ea Email: [email protected] Web: bighornlaw.com

(a □□□ LAS VEGAS Ae Sp poe

This email and any attachments are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please contact the sender(s) at (702) 333-1111 and delete all copies from your system. Please note that any opinions in this email are solely those of the author and do not necessarily represent those of Bighorn Law, and is not to be considered legal advice.