1 Christopher M. Humes, Esq. Nevada Bar No. 12782 2 William D. Nobriga, Esq. Nevada Bar No. 14931 3 BROWNSTEIN HYATT FARBER SCHRECK, LLP 4 100 North City Parkway, Suite 1600 Las Vegas, Nevada 89106 5 Telephone: (702) 382-2101 Facsimile: (702) 382-8135 6 Email: [email protected] [email protected] 7

8 Attorneys for Plaintiffs

9 UNITED STATES DISTRICT COURT

10 DISTRICT OF NEVADA 11 BOARD OF TRUSTEES OF THE Case No. 2:24-cv-00686-JCM-BNW 12 ELECTRICAL WORKERS HEALTH AND WELFARE TRUST; BOARD OF 13 TRUSTEES OF THE ELECTRICAL WORKERS PENSION TRUST, 14

15 Plaintiffs, JOINT REQUEST FOR EXTENSION OF 16 vs. STAY IN PROCEEDINGS

17 LAM CONTRACTING, LLC, a Nevada (FIRST REQUEST) limited liability company, 18

19 Defendant.

20 21 Plaintiffs, Boards of Trustees of the Electrical Workers Health and Welfare Trust and the 22 Electrical Workers Pension Trust (the “Trust Funds”) and LAM Contracting, LLC (“LAM”), by 23 and through their respective counsel of record, jointly move this Court to extend the current stay 24 of proceedings by thirty (30) days, until September 10, 2025, to allow the parties to complete their 25 obligations under the current fully-executed settlement agreement. 26 1. On June 2, 2025, the Trust Funds filed a Motion to Compel and a Motion for 27 Discovery Sanctions against LAM. See ECF Nos. 9 & 10. 1 2. On June 3, 2025, this Court issued an order expediting the briefing schedule and 2 setting a hearing on the pending discovery motions for June 13, 2025. See ECF No. 11. 3 3. On June 11, 2025, the parties filed a joint request to, among other things, vacate 4 the June 13, 2025, hearing due to the parties believing they had reached an agreement in principle 5 to resolve the instant dispute. See ECF No. 15. 6 4. On June 12, 2025, The Court granted the parties’ requests and issued a stay in 7 discovery for sixty (60) days, which ends on August 11, 2025. See ECF No. 17. 8 5. The parties have memorialized the terms of their agreement to resolve this dispute, 9 with the parties predicted to have completed all obligations under the fully-executed settlement 10 agreement by August 21, 2025. 11 Given that the parties have come to an agreement to resolve this case and that the 12 obligations under the current settlement agreement will very likely be completed by August 21, 13 2025, the parties jointly request that the current stay of proceedings be extended by thirty (30) 14 additional days, to September 10, 2025. 15 As this Court knows, it has “inherent authority to stay federal proceedings pursuant to its 16 docket management powers.” Ernest Bock, LLC v. Steelman,

, 842 (9th Cir. 2023The 17 Ninth Circuit has “identified three non-exclusive factors courts must weigh when deciding 18 whether to issue a docket management stay: (1) the possible damage which may result from the 19 granting of a stay; (2) the hardship or inequity which a party may suffer in being required to go 20 forward; and (3) the orderly course of justice measured in terms of the simplifying or 21 complicating of issues, proof, and questions of law.” In re PG&E Corp. Sec. Litig.,

1076, 1085 (9th Cir. 2024) (quoting Ernest Bock, 76 F.4th at 842) (quotations omitted). 23 None of the factors above are implicated here, nor is this extension sought for the purpose 24 of delay. The parties jointly request this stay to allow for additional time to complete their 25 obligations under a fully-executed settlement agreement and prepare a joint request for dismissal 26 of this case. This stay would benefit both sides to this dispute, as well as conserve resources for 27 all involved, and is why this request is jointly brought. 1 The parties therefore request that the current stay of proceedings be extended t 2 || September 10, 2025. If no stipulation to dismiss this case has been filed by that date, the partie 3 || will file a joint status report on or before September 10, 2025, outlining the current status of th 4 || parties’ resolution of this case, or lack thereof. 6 || Dated: August 11, 2025. 7 || BROWNSTEIN HYATT FARBER JACKSON LEWIS, P.C. g || SCHRECK, LLP 9 ||/s/ Christopher M. Humes /s/ Paul T. Trimmer Christopher M. Humes, Esq. Paul T. Trimmer, Esq. 10 |] Nevada Bar No. 12782 Nevada Bar No. 9291 ll William D. Nobriga, Esq. 300 South Fourth Street, Suite 900 Nevada Bar No. 14931 Las Vegas, Nevada 89101 12 || 100 North City Parkway, Suite 1600 Telephone: (702) 921-2460 Las Vegas, Nevada 89106-4614 Facsimile: (702) 921-2461 13 || Telephone: (702) 382-2101 Email : Paul. [email protected] Facsimile: (702) 382-8135 14 |) Email: [email protected] : Attorney for Defendant 15 Email: [email protected]

16 || Attorneys for Plaintiffs 17 ORDER 18 IT IS SO ORDERED. 19 20 21 22 Ke, pw la pe bad 3 UNITED STATES MAGISTRATE JUDGE DATED: August 13, 2025

Case No. 2:24-cv-00686-JCM-BNW 26 27 28