1 || Gustavo Ponce, Esq. > Nevada Bar No. 15084 Mona Amini, Esq. 3 || Nevada Bar No. 15381 4 KAZEROUNI LAW GROUP, APC 6940 S. Cimarron Rd., Suite 210 5 || Las Vegas, Nevada 89113 6 || Telephone: (800) 400-6808 Facsimile: (800) 520-5523 7 || E-mail: [email protected] g || E-mail: [email protected] 9 || Attorneys for Plaintiff 10 Erin Robertson

O 11 Ps D UNITED STATES DISTRICT COURT DISTRICT OF NEVADA © 14 ERIN ROBERTSON, individually and on Case No.: 3:24-cv-00439-ART-CSD = 45 □□ < behalf of all others similarly situated, JOINT STIPULATION AND ORDER EXTENDING CASE 17 Lo. DEADLINES AND Plaintiff, DEFENDANT’S ANSWER 18 DEADLINE

20 || FIDELITY LIFE ASSOCIATION, (PARTIES’ FIRST REQUEST) 22 Defendant. 23 77) 24 Vy) 29 V1) 26 27 28

1 Plaintiff ERIN ROBERTSON (“Plaintiff”) and Defendant FIDELITY LIFE 2 || ASSOCIATION (“Defendant”), (jointly all as the “Parties”), hereby jointly move to 3 |lextend Defendant’s time to respond to the Complaint by fifteen (15) days and all 4 || other case deadlines by a period of one hundred and fifty (150) days, following the > decision from this Court on Defendant’s Motion to Dismiss (ECF No. 32). The 6 || requested extension will allow the Parties to discuss potential resolution as well as 7 | allow the Parties adequate time to conduct class and other discovery if a resolution is 8 ||not obtained. The Parties have conferred and agree that this extension is supported by 9 || good cause as the most reasonable, most economical, and least burdensome way to 10 || proceed in this case. L Good Cause for Extension 12 On September 19, 2025, this Court denied Defendant’s January 21, 2025 13 || Motion to Dismiss (ECF No. 32). While that motion was pending, the Parties 5 14 || prudently limited activity to exchanging initial disclosures and deferred further 15 || discovery in order to conserve resources that may not have been necessary to expend 16 |!1f the motion to dismiss was granted. Now that the pleadings are settled, the Parties 17 seek time to commensurate with the original scheduling order to: 18 e Conduct written discovery, including class discovery; 19 Take fact and third-party depositions; 20 « Brief dispositive motions; 21 « Address potential expert discovery; and 22 « Explore potential resolution. 23 Good cause exists for this requested extension because it will enable the Parties 24 || to efficiently complete necessary discovery, reduce the likelihood of discovery 25 || disputes, and potentially engage in meaningful settlement discussions before 26 ||expending additional resources. See, e.g., Coffee v. Wyndham Resort Dev. Corp., No. 27 || 2:20-CV-1352-APG-DJA,

(D. Nev. Jan. 15, 2021). The Parties also 28 || agree that the very modest 15-day extension to Defendant’s Answer deadline is

1 || appropriate, as it will not prejudice any party and will facilitate the orderly 2 || investigation of the factual allegations and affirmative defenses in this case. 3|| II. Procedural History 4 1. Plaintiff filed her Complaint on September 25, 2024 (ECF No. 1). 5 2. On November 21, 2024, Defendant obtained an extension to respond to the 6 Complaint (ECF No. 4). 7 3. On January 21, 2025, Defendant moved to dismiss (ECF No. 13). 8 4. On January 31, 2025, the Court granted the Parties’ stipulation to extend 9 briefing deadlines (ECF No. 16). 10 5. Plaintiff filed her Opposition on February 18, 2025 (ECF No. 20). O 11 6. On February 24, 2025, the Court granted Defendant’s request to extend time to 12 file its Reply (ECF No. 25). 13 7. Defendant filed its Reply on March 4, 2025 (ECF No. 31). 5 14 8. On September 19, 2025, the Court denied Defendant’s Motion to Dismiss 15 (ECF No. 32). 16 9. This is the Parties’ first request to extend the Scheduling Order deadlines (ECF 17 No. 28). 18 Discovery Position 19 To date, the Parties have exchanged initial disclosures and conferred regarding the 20 || scope of discovery, but in light of Defendant’s pending Motion to Dismiss, the 21 || Parties mutually agreed to conserve resources by deferring propounding full written 22 || discovery and depositions, given that the substantial time and expense required to 23 || conduct such discovery would not be required if the Motion to Dismiss were granted. 24 || With the Motion to Dismiss now resolved, the Parties seek a modest extension of 25 || time to allow them to complete discovery, including written interrogatories and 26 || document requests, third-party subpoenas, and depositions of fact witnesses and Rule 27 ||30(b)(6) designees. The Parties also anticipate that expert discovery may be required. 28 || Additional time is therefore necessary to allow the Parties to fully and fairly complete

1 || discovery, address any issues that may arise, and meaningfully explore resolution 2 || before incurring the expense of expert work and trial preparation. 3 IV. Good Faith Request 4 This is the Parties’ first request for an extension. The request is made jointly, in > || good faith, and not for purposes of delay. No party will be prejudiced; to the contrary, 6 || granting additional time will promote judicial economy by allowing the case to 7 || proceed in an orderly and efficient manner, reducing the likelihood of unnecessary 8 || motion practice, and giving the Parties the opportunity to address discovery issues 9 || cooperatively and in good faith rather than through piecemeal disputes or rushed 10 || deadlines. Il] Vv. Current Deadlines and Proposed Deadlines 12 The current deadlines per the Amended Stipulated Discovery Plan and 13 || Scheduling Order are as follows: 5 14 Defendant’s Answer Deadline 10/06/2025 15 Deadline to File Motion for Class Certification 11/21/2025 16 Deadline to Disclose Expert Disclosures 12/21/2025 17 Discovery Cut-off 2/19/2026 18 Deadline to File Dispositive Motions 3/20/2026 19 Pre-Trial Order 4/20/2026 20 For the reasons explained in this Stipulation, the Parties request adoption of the 21 || following deadlines: 22 Defendant’s Answer Deadline 10/21/2025 23 Deadline to File Motion for Class Certification 4/20/2026 24 Deadline to Disclose Expert Disclosures 5/20/2026 25 Discovery Cut-off 7/20/2026 26 Deadline to File Dispositive Motions 8/17/2026 27 The parties request that the deadline for filing a joint pretrial order be set no 28 || later than 9/17/2026 or thirty (30) days after the date set for filing dispositive

1 || motions. If any Party files a dispositive motion, the Parties request that the date for 2 | filing the joint pretrial order be suspended until thirty (30) days after decision on the 3 || dispositive motion or further order of the Court. 4 WHEREFORE, Plaintiff and Defendant respectfully request this Honorable > ||Court (1) extend deadlines in the present matter as set forth above; and (2) reissue a 6 ||new Scheduling Order to reflect the requested extension. 7 || DATED: 9/30/2025 DATED: 9/30/2025 8 KAZEROUNI LAW GROUP, APC PERKINS COIE LLP 10 || By: /s/ Gustavo Ponce Gustavo Ponce, Esq 2 , By: /s/ James Snell |! | Mona Amini, Esq. James G. Snell (pro hac vice) 6940 S. Cimarron Rd., Suite 210 ; . 2 Saroop Kaur Sandhu (pro hac vice) Las Vegas, Nevada 89113 . = 13 || Attorneys for Plaintiff 3150 Porter Drive O Palo Alto, California 94304-1212 14 KING SCOW KOCH DURHAM = 15 = LLC 16 David R. Koch, 4 11500 S. Eastern Ave., Suite 210 Henderson, Nevada 89052 18 Attorneys for Defendant 19 ORDER 2] IT IS SO ORDERED. 22 CS 24 35 UNITED STATES GISTRATE JUDGE

26 DATED: October1,2025 00 27 28