| Sdat BANG Gots: ESQ: 2 || RICHARD HARRIS LAW FIRM 801 South Fourth Street 3 || Las Vegas, Nevada 89101 P: (702) 444-4444 4 || F: (702) 444-4455 5 E: [email protected] Attorneys for Plaintiff 6 BRETT A. SHUMATE 7 || Assistant Attorney General SIGAL CHATTAH g || Acting United States Attorney GAVIN J. HALLISEY 9 || Trial Attorney U.S. Department of Justice 10 }| Civil Division, Torts Branch Post Office Box 14271 11 |) Washington, D.C. 20044-4271 (202) 307-1030 12 || [email protected] Attorneys for United States of America 14 UNITED STATES DISTRICT COURT

15 DISTRICT OF NEVADA 16 MATT BINNER, individually CASE NO.: = 2:25-cv-00712-JAD-EJY 17 Plaintiff, 18 VS. STIPULATION AND ORDER TO STAY 19 DISCOVERY AND ALL CASE DEADLINES PENDING THE COURT’S 20 | UNITED STATES OF AMERICA, RULING ON DEFENDANT’S MOTION 1 Defendant. TO DISMISS [ECF 8] 22 IT IS HEREBY STIPULATED by and between Plaintiff Matt Binner, through his 23 || counsel of record Mysty Langford, Esq. of the Richard Harris Law Firm, and Defendant United 24 Il States of America by and through its counsel of record Gavin J. Hallisey, Esq., of the U.S. 25 Department of Justice, (collectively “Parties”), that all discovery and case deadlines be stayed 26 until the disposition of Defendant’s pending motion to dismiss [ECF 8]. This stipulation is 27 submitted and based upon the following: 28 1. This is the Parties’ first request for a stay of discovery.

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1 2. On June 27, 2025, Defendant filed in motion to dismiss [ECF 8] (“Motion to 2 Dismiss’). 3 4 3. On July 10, 2025, Plaintiff filed his opposition and countermotion to amend

5 complaint [ECF 11]. 6 4. On July 17, 2025, Defendant filed its reply in support of Motion to Dismiss [ECF 12]. 7 5. The Motion to Dismiss remains pending before the Court. 8 6. The Parties acknowledge their obligations under Fed. R. Civ. P. 26 but agree that a 9 stay of discovery is appropriate until the Court rules on Defendant’s Motion to 10 Dismiss, which raises a statute of limitations defense under Fed. R. Civ. P. 12(b)(6). 11 7. In addition, given the pendency of Defendant’s Motion to Dismiss, the Parties desire 12 to avoid the time and expense of imminent discovery deadlines and to avoid

13 inefficiently using judicial resources on potentially unnecessary discovery disputes or a x 14 motion practice. . . Courts in this District have recognized that a discovery stay is warranted where a &B 8. C his D h gnized that a d y stay dwh

16 pending dispositive motion may resolve the action in its entirety or substantially M7 narrow the issues for discovery.

18 9. Accordingly, the Parties have agreed to stay all discovery and case deadlines until the 19 disposition of Defendant’s Motion to Dismiss in order to conserve the Parties’ 20 resources and for the sake of judicial economy. 21 10. It is well recognized that “[c]ourts have broad discretion in managing their dockets.” 22 33 Byars v. Western Best, LLC, No. 2:19-CV-1690-JCM-DJA,

, at *1

54 (D. Nev. Jul. 6, 2020), citing Clinton v. Jones,

(1997). In exercising such discretion, “courts are guided by the goals of securing the just, %6 speedy, and inexpensive resolution of actions.” /d.; see also Fed. R. Civ. P. 1. The 7 Parties agree that good cause exists to stay discovery and all case deadlines while 28 Defendant’s Motion to Dismiss remains pending, which might effectively suspend or dispose of this action or certain of Plaintiffs’ claims. See Schrader v. Wynn Las

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1 Vegas, LLC, No. 2:19-cv-02159-JCM-BNW,

, at *4 (D. Nev. Oct. 2 14, 2021); Aristocrat Techs., Inc. v. Light & Wonder, Inc., No. 2:24-CV-00382- 3 4 GMN-MDC,

, at *1 (D. Nev. May 21, 2024). 5 11. Proceeding with discovery before Defendant’s Motion to Dismiss 1s resolved could 6 cause unnecessary expense to the Parties, particularly because this is a complicated 7 matter which may ultimately be consolidated with four other pending cases, and g which may clog the Court’s docket with potentially unnecessary discovery disputes or 9 motion practice. 10 12. Consistent with the foregoing, the Parties believe they will be in a better position to 11 resume discovery once Defendant’s Motion to Dismiss is resolved. 12 13. For all these reasons, the Parties believe it is in the interest of judicial efficiency and

13 economy to stay discovery and all case deadlines until the disposition of Defendant’s a x 14 Motion to Dismiss. 15 14. In the event that Defendant’s Motion to Dismiss is denied, the Parties will submit a < 16 Discovery Plan and Scheduling Order (“DPSO”) within 14 days after Defendant files its Answer. This DPSO set discovery or case deadlines pro rata from the date of the

18 Court’s ruling on Defendant’s Motion to Dismiss, or as the Parties may otherwise 19 agree or deem necessary. 20 15. The Parties further agree that they are not waiving, relinquishing, or otherwise 21 22 23 24 25 26 27 28

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1 impairing any claim, defense, or other right they may have by virtue of entering into 2 this Stipulation. 3 4 DATED this 17th day of September 2025. DATED this 18th day of September 2025. RICHARD HARRIS LAW FIRM U.S. DEPARTMENT OF JUSTICE 5 6 /s/ Mysty Langford /s/ Gavin J. Hallisey 7 || MYSTY LANGFORD, ESQ. GAVIN J. HALLISEY Nevada Bar No. 16909 Trial Attorney 8 801 South Fourth Street Aviation, Space & Admiralty Litigation Las Vegas, NV 89101 Torts Branch, Civil Division 9 ? Attorneys for Plaintiff U.S. Department of Justice 10 P.O. Box 14271 Washington, DC 20044-4271 1 (202) 307-1030 Gavin. [email protected] Attorney for Defendant 13

14 15 = IT IS SO ORDERED. ‘ 16 17 18 19 UNITED STAT : STRATE JUDGE 20 DATED: September 18, 2025 22 23 24 25 26 27 28

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