RESNICK & LOUIS, P.C. 11 CARISSA YUHAS, ESQ. Nevada Bar No. 14692 22 [email protected] 8945 West Russell Road, Suite 330 33 Las Vegas, Nevada 89148 44 Telephone: (702) 997-3800 Facsimile: (702) 997-3800 55 Attorney for Defendant, LOVE’S TRAVEL STOPS & 66 COUNTRY STORES, INC. 77 UNITED STATES DISTRICT COURT 8 8 DISTRICT OF NEVADA 9 9 SHEILA MILLER, individually, CASE NO.: 2:24-cv-02410 10 10 11 Plaintiff, STIPULATION AND PROPOSED 11 ORDER TO EXTEND DISCOVERY 12 vs. DEADLINES 12 13 13 LOVE’S TRAVEL STOPS & COUNTRY (THIRD REQUEST) 14 STORES, INC., an Oklahoma Corporation; 14 GRANT THORNTON, LLP, a Foreign 15 Limited-Liability Partnership; and DOES I-X; 15 and ROE BUSINESS ENTITIES XI-XX, 16 inclusive. 16 17 Defendants 17 18 18 19 IT IS HEREBY STIPULATED by and between Plaintiff, SHEILA MILLER, through her 19 20 20 attorney, KIRILL V. MIKHAYLOV, ESQ., of PACIFIC WEST INJURY LAW, and Defendant, 21 21 LOVE’S TRAVEL STOPS & COUNTRY STORES, INC., through their attorney, CARISSA 22 2 2 2 3 YUHAS, ESQ. of RESNICK & LOUIS, P.C., that good cause existing and pursuant to Local Rule 23 24 26-1(b), discovery in this matter shall be extended an additional sixty (60) days for the purpose of 2245 completing the discovery described herein. 2256 2267 I. DISCOVERY WHICH HAS BEEN COMPLETED 11 2. Plaintiff has produced her Lists of Witnesses and Documents, and supplements 22 thereto pursuant to FRCP 26(a). 33 3. Defendant has produced its Lists of Witnesses and Documents, and supplements 44 thereto pursuant to FRCP 26(a). 55 4. Defendant propounded First Set of Interrogatories to Plaintiff. 66 5. Defendant propounded First Set of Requests for Production to Plaintiff. 77 6. Defendant propounded First Set of Request for Admissions to Plaintiff. 8 8 7. Plaintiff served Responses to Defendant’s First Set of Interrogatories. 9 9 8. Plaintiff served Responses to Defendant’s First Set of Requests for Production. 1 1 0 0 9. Plaintiff served Responses to Defendant’s First Set of Request for Admissions. 1 1 1 1 10. Plaintiff propounded First Set of Interrogatories to Defendant. 12 11. Plaintiff propounded First Set of Requests for Production to Defendant. 12 13 12. Plaintiff propounded First Set of Request for Admissions to Defendant. 13 14 13. Defendant served Responses to Plaintiff’s First Set of Interrogatories. 14 15 14. Defendant served Responses to Plaintiff’s First Set of Requests for Production. 15 16 15. Defendant served Responses to Plaintiff’s First Set of Request for Admissions. 16 17 16. The parties conducted Plaintiff’s deposition. 17 18 17. Defendant served its Initial Disclosure of Expert Witnesses and supplements 18 19 thereto pursuant to FRCP 26(a). 19 20 18. Plaintiff served her Initial Disclosure of Expert Witnesses. 20 21 II. DISCOVERY THAT REMAINS TO BE COMPLETED 21 22 1. Deposition of Defendant Love’s Travel Stops & Country Stores, Inc. 30(b)(6) 22 23 witness(es) (the parties are currently coordinating) 23 24 2. Potential NRCP 35 exam of Plaintiff (currently pending information from 2245 Plaintiff’s updated treatment records); 2256 3. Depositions of Plaintiff’s treating physician(s); 2267 11 4. Depositions of the parties’ respective experts; and 22 5. Additional discovery as needed. 33 The Parties anticipate that they may need to conduct other forms of discovery, though not 44 specifically delineated herein, and anticipate doing so only on an as-needed basis. 55 III. REASONS DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS 66 AND NEEDS TO BE EXTENDED 77 LR 26-3 governs modifications or extension of the Discovery Plan and Scheduling Order. 8 8 Any stipulation or motion to extend or modify that Discovery Plan and Scheduling Order must 9 9 be made no later than twenty-one (21) days before the expiration of the subject deadline and must 1 1 0 0 comply fully with LR 26-3. If the stipulation is made less than twenty-one (21) days before the 1 1 1 1 expiration of a deadline, the parties must show a good cause exist. A request made after the 12 expiration of the subject deadline will not be granted unless the movant also demonstrates that 12 13 the failure to act was the result of excusable neglect. 13 14 A request to extend unexpired deadlines in the scheduling order must be premised on a 14 15 showing of good cause. Fed. R. Civ. P. 16(b)(4); Local Rule 26-3. The good cause analysis turns 15 16 on whether the subject deadlines cannot reasonably be met despite the exercise of diligence. 16 17 Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). 17 18 The parties respectfully submit, pursuant to Local Rule 26-3, that good cause and 18 19 excusable neglect exist for the following requested extension. Although the parties have been 19 20 diligently working on this matter, due to Plaintiff resuming treatment with Jonathan Kletter, PA- 20 21 C of Reconstructive Orthopaedics of Central Florida for her left knee, the parties have been unable 21 22 to obtain all current medical records relevant to Plaintiff’s claimed injuries in this matter. The 22 23 parties need to obtain Plaintiff’s latest medical records and evaluate the need to address future 23 24 treatment and a potential NRCP 35 examination (which if needed, will involve travel planning 2245 and additional time since Plaintiff’s work schedule as a truck driver often requires her to be in 2256 different states). The parties have requested said information from Reconstructive Orthopaedics 2267 of Central Florida but have not yet received responses to which the parties have no control. ] Lastly, the parties are in the process of scheduling the deposition of Defendant’s 30(b)(6) 2 || witness. The parties have been working together with lengthy discussions to reach agreeable 3 || terms for the deposition in order to avoid Court intervention and require additional time to prepare 4 || the witness and schedule the deposition. 5 This Request for an extension of time is not sought for any improper purpose other 6 || purpose of delay. Despite both parties’ efforts, they have been precluded from fully investigating 7 || the merits of this case through necessary discovery. Based on the foregoing, both Plaintiff and 8 || Defense counsel are requesting that the discovery deadlines be extended by sixty (60) days. 9 V. MODIFICATION OF THE DISCOVERY PLAN AND SCHEDULING ORDER 10 11 Discovery Deadline Current Deadline Proposed Deadline Motion to Amend/Add Parties April 22, 2025 12 Initial Expert Disclosures June 23, 2025 13 ||| All Rebuttal Expert Disclosures July 21, 2025 Discovery Cut-Off Date October 20, 2025 December 19, 2025 14 November 18, 2025 January 20, 2026 15 The parties represent this Stipulation is sought in good faith and not interposed for dela 16 || Or any other improper purpose. 17 DATED this 6" day of October, 2025. DATED this 6™ day of October, 2025. 18 PACIFIC WEST INJURY LAW RESNICK & LOUIS, P.C. 19 /s/ Kirill V. Mikhaylov /s/Carissa Yuhas 20 21 |] KRISTOPHER M. HELMICK, ESQ. CARISSA YUHAS, ESQ. Nevada Bar No. 13348 Nevada Bar No. 14692 22 || KIRILL V. MIKHAYLOV, ESQ. 8945 W. Russell Road, Suite 330 Nevada Bar No. 13538 Las Vegas, NV 89148 23 || BOHDEN G. COLE, ESQ. Attorney for Defendant Nevada Bar No. 15719 LOVE’S TRAVEL STOPS & 24 || 8180 Rafael Rivera Way #200 COUNTRY STORES, INC 35 Las Vegas, NV 89113 Attorneys for Plaintiff IT IS SO ORDERED 2 6 DATED: 8:42 pm, October 07, 2025 27