1 ADAM J. BREEDEN, ESQ. Nevada Bar No. 008768 2 ALYSSA N. PIRAINO, ESQ. Nevada Bar No. 14601 3 BREEDEN & ASSOCIATES, PLLC 7432 W. Sahara Ave., Suite 101 4 Las Vegas, Nevada 89117 Phone: (702) 819-7770 5 Fax: (702) 819-7771 [email protected] 6 [email protected] Attorneys for Plaintiff 7

8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 DEREK MYERS, on behalf of himself and all others similarly situated, 11 Plaintiff, CASE NO. 2:25-cv-00562-GMN-DJA 12 v. 13 CITY OF LAS VEGAS, a political 14 subdivision of the state of Nevada; JASON STIPULATION AND PROPOSED ORDER BROOKS, individually; SERGIO GUZMAN, TO STAY DISCOVERY 15 individually; and JASON POTTS, 16 individually,

17 Defendants.

18 IT IS HEREBY STIPULATED between Plaintiff, DEREK MEYERS, by and through his 19 counsel Adam J. Breeden, Esq. and Alyssa N. Piraino, Esq. of BREEDEN & ASSOCIATES, PLLC, 20 and Defendants, CITY OF LAS VEGAS, JASON BROOKS, SERGIO GUZMAN, and JASON 21 POTTS, by and through their counsel of record Nechole Garcia, Esq. (hereinafter referred to as 22 “Defendants”), that: 23 WHEREAS on June 27, 2025 the Court granted the Discovery Plan and Scheduling Order 24 [ECF No. 22] setting forth the deadlines for this matter. 25 WHEREAS on August 18, 2025 Plaintiff filed his Motion for Class Action Certification 26 [ECF No. 24]. The outcome of this Motion is currently pending. 27 1 WHEREAS the parties have exchanged initial disclosures and written discovery in the form 2 || of Interrogatories, Requests for Admission and Requests for Documents. Expert disclosures and 3 || depositions remain to be conducted. 4 WHEREAS, the outcome of the Motion for Class Action Certification is currently pending, 5 || and based on the outcome of this motion, it will greatly affect various areas of remaining discovery 6 || to be conducted. Therefore; 7 IT IS HEREBY STIPULATED that all current discovery deadlines in this matter are stayed 8 || pending the adjudication of the Motion for Class Action Certification [ECF No. 24]. The parties 9 || agree to complete any currently outstanding written discovery during the stay, but will not initiate 10 || any new written discovery or take depositions. Following adjudication of that motion, the Parties 11 || will meet and confer to submit a new Discovery Plan and Scheduling Order setting forth new dates. 12 IT IS SO STIPULATED AND AGREED. 13 || Dated this 4 day of November, 2025. Dated this 4" day of November, 2025. 14|| BREEDEN & ASSOCIATES, PLLC CITY ATTORNEY || /s/ Adam J. Breeden /s/ Nechole Garcia, Esq. || ADAM J. BREEDEN, ESQ. NECHOIE CARCIA FSQ..SO~S™ Nevada Bar No. 008768 Ne. one ESQ. || 7432 W. Sahara Ave., Suite 101 ovate aT NG! Las Vegas, Nevada 89117 Chief Deputy City Attorney 18 || Phone: (702) 819-7770 PAUL MATA, ESQ. Fax: (702) 819-7771 Nevada Bar No. 14922 19 || [email protected] Deputy City Attorney 20 Attorneys for Plaintiffs 495 S. Main Street, Sixth Floor Las Vegas, NV 89101 1 Attorneys for Defendants Having reviewed the parties’ stipulation, the Court finds that they have demonstrated good cause 22 to stay discovery pending the outcome of the motion to certify class. See Schrader v. Wynn, No. || 2:19-cv-02159-JCM-BNW,

(D. Nev. Oct. 14, 2021). IT IS THEREFORE ORDERED that the stipulation (ECF No. 28) is GRANTED. IT IS FURTHER ORDERED that || the parties must submit a new discovery plan and scheduling order within thirty days of the 36 Court's order on the motion to certify class.

27 DANIEL J. ALBREGTS 8 UNITED STATES MAGISTRATE JUDGE DATED: November 5, 2025