1 TYSON & MENDES LLP 2 GRIFFITH H. HAYES Nevada Bar No. 7374 3 TYRUS COBB Nevada Bar No. 8031 4 Email(s): [email protected] [email protected] 5 2835 St. Rose Pkwy., Suite 140 Henderson, NV 89052 6 Telephone: (702) 724-2648 Facsimile: (702) 410-7684 7 Attorneys for Defendant Walmart, Inc.

8 UNITED STATES DISTRICT COURT

9 DISTRICT OF NEVADA

10 DENISE MARIE BALLARD, Case No. 2:25-cv-00866 -JAD -NJK

11 Plaintiff,

12 v. STIPULATION AND PROPOSED ORDER TO EXTEND DISCOVERY DEADLINES 13 WALMART, INC., a Foreign Corporation d/b/a Walmart #1584; DOES I through X; and (FIRST REQUEST) 14 ROE CORPORATIONS I through X, inclusive, 15 Defendants. 16

17 18 IT IS HEREBY STIPULATED AND AGREED, between the parties and their 19 attorneys of record, that the current discovery deadlines to be extended as indicated on page 3, 20 pursuant to Local Rule 26-1(b) and 26-4. 21 I. DISCOVERY COMPLETED TO DATE 22 1. The parties have conducted the FRCP 26.1 Early Case Conference. 23 2. Defendant produced its Lists of Witnesses and Documents on June 19, 2025, 24 3. Plaintiff produced her Lists of Witnesses and Documents on June 3, 2025. 25 4. Plaintiff produced her First Supplement to Lists of Witnesses and Documents on 26 June 17, 2025. 27 5. Plaintiff propounded her First Set of Interrogatories (25 Interrogatories), Requests 28 1 for Production of Documents (25 Requests) to Defendant on July 3, 2025. 2 6. Defendant propounded its First Set of Interrogatories (25 Interrogatories), Requests 3 for Production of Documents (32 Requests), and Requests for Admissions (26 Requests) to 4 Plaintiff on August 19, 2025. 5 II. 6 DISCOVERY THAT REMAINS TO BE COMPLETED

7 1. Responses of Plaintiff to Defendant’s First Set of Interrogatories (25 8 Interrogatories), Requests for Production of Documents (32 Requests), and 9 Requests for Admissions (26 Requests). 10 2. Responses of Defendant to Plaintiff’s First Set of Interrogatories (25 11 Interrogatories), Requests for Production of Documents (25 Requests). 12 3. Rule 35 Examination of Plaintiff. 13 4. Deposition of Plaintiff. 14 5. Inspection of the premises. 15 6. Deposition of Defendant Walmart, Inc. 30(b)(6) witness(es). 16 7. Designation of Initial Experts. 17 8. Designation of Rebuttal Experts. 18 9. Deposition(s) of Plaintiff’s treating physicians. 19 10. Deposition of other percipient witnesses. 20 11. Depositions of experts. 21 12. Additional written discovery (if necessary). 22 13. Any remaining discovery the parties deem relevant and necessary as discovery 23 continues. 24 III. 25 WHY DISCOVERY CANNOT BE COMPLETED WITHIN THE TIME PROVIDED BY THE CURRENT SCHEDULING ORDER 26 27 A. Good Cause 28 LR 26-4 governs modifications or extension of the Discovery Plan and Scheduling Order. 1 Any stipulation or motion to extend or modify that Discovery Plan and Scheduling Order must be 2 made no later than twenty-one (21) days before the expiration of the subject deadline and must 3 comply fully with LR 26-4. If the stipulation is made less than twenty-one (21) days before the 4 expiration of a deadline, the parties must show a good cause exist. A request made after the 5 expiration of the subject deadline will not be granted unless the movant also demonstrates that the 6 failure to act was the result of excusable neglect. 7 A request to extend unexpired deadlines in the scheduling order must be premised on a 8 showing of good cause. Fed. R. Civ. P. 16(b)(4); Local Rule 26-3. The good cause analysis turns 9 on whether the subject deadlines cannot reasonably be met despite the exercise of diligence. 10 Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). 11 Good cause exists for the following reasons: the parties have scheduled a mediation 12 session for September 18, 2025 and are attempting to resolve this case without incurring 13 unnecessary expenses, including costs associated with retention or experts. The parties agreed to 14 extend all the current discovery deadlines by 60 days subject to the approval of this court. 15 IV. 16 PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY

17 Discovery Deadline Current Deadline Proposed Deadline 18 Motion to Amend/Add Parties June 18, 2025 June 18, 2025 Initial Expert Disclosures October 20, 2025 December 19, 2025 19 All Rebuttal Expert Disclosures November 19, 2025 January 19, 2026 20 Discovery Cut-Off Date December 19, 2025 February 17, 2026 Dispositive Motions January 19, 2026 March 20, 2026 21 Pretrial Order February 18, 2026 April 20, 2026 or 30 days after 22 resolution of dispositive 23 motions

24 25 /// 26 /// 27 /// 28 /// ] The parties represent this Stipulation is sought in good faith and with excusable neglect 2 || and not interposed for delay or any other improper purpose. 3 Dated this 29" day of August, 2025. Dated this 29" day of August, 2025. 4 TYSON & MENDES LLP MOSS BERG INJURY LAWYERS 6 || 4s/ Griffith H. Hayes /s/Bovd Moss GRIFFITH H. HAYES BOYD B. MOSS 7 Nevada Bar No. 7374 Nevada Bar No. 8856 g || TYRUS COBB JOHN C. FUNK Nevada Bar No. 8031 2835 St. Rose Pkwy., Suite 140 Nevada Bar No. 9255 . 9 5420 West Sahara Avenue, Suite 101 Henderson, NV 89052 Attorneys for Defendant Walmart, Inc Las Vegas, Nevada 89146 10 — Attorneys for Plaintiff 1] | This stipulation includes several incorrect rules citations, but the relief sought is 12 || GRANTED. In addition, a joint status report regarding mediation must be filed by September 25, 2025. 13 IT IS SO ORDERED. 14 UNITED STATES MAGISTRATE JUDGE 16 — \ 17 DATED: August 29, 2025 18 19 20 21 22 23 24 25 26 27 28