Dora V. Lane, Esq. (NV Bar No. 8424) 1 Ascent Law, PC 2 5470 Kietzke Lane, Ste. 300 Reno, NV 89511-2099 3 Telephone: (775) 671-6171 Email: [email protected] 4 Attorney for Defendant 5 Las Vegas Valley Water District 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 9 RYAN LUZIER, CASE NO. 2:25-cv-01512 10 Plaintiff STIPULATION TO STAY 11 v. DISCOVERY AND VACATE HEARING ON DEFENDANT’S 12 LAS VEGAS VALLEY WATER DISTRICT, MOTION TO STAY DISCOVERY 13 DOES I through X; and Roe Corporations I PENDING MOTION TO DISMISS FOR through X, inclusive, FAILURE TO STATE A CLAIM 14 Defendant 15 16 Pursuant to Local Rule (“LR”) IA 6-1, Plaintiff Ryan Luzier (“Luzier”) and Defendant Las 17 Vegas Valley Water District (the “District”) (collectively, the “Parties”) agree and stipulate as 18 follows: 19 1. Upon further conferral on December 2, 2025, for the reasons expressed in the 20 District’s Motion to Stay Discovery Pending Motion to Dismiss for Failure to State a Claim (the 21 “Motion to Stay”) (ECF # 16), the Parties have agreed to stay discovery until March 13, 2026, or 22 until the District Court rules on the District’s Motion to Dismiss (ECF # 8)—whichever is sooner. 23 3. The Court has set a hearing on the District’s Motion to Stay for Tuesday, December 24 16, 2025, at 1:30 p.m. (ECF # 17). Given the Parties’ current stipulation to stay discovery as 25 described above, the Parties respectfully request that the Court vacate the December 16, 2025, 26 27 1 || hearing and enter an order staying discovery until March 13, 2026, or until the District Court rules on the District’s Motion to Dismiss, whichever is earlier. 3 Date: December 3, 2025 Respectfully submitted, 5 6 /s/ Dora Lane /s/Erik Fitting Dora Lane, Esq. Erik Fitting, Esq. Ascent Law, PC Erik Fitting & Associates, LTD. 5470 Kietzke Lane, Ste. 300 2450 St. Rose Parkway, Suite 110 8 || Reno, NV 89511-2099 Henderson, Nevada 89074 Telephone: (775) 671-6171 Telephone: (702) 312-6965 || Email: [email protected] Email: [email protected] 10 Attorney for Defendant Attorney for Plaintiff 11 || Las Vegas Valley Water District Ryan Luzier 12 The Court finds that the parties have shown good cause and therefore grants the stipulation to stay discovery. (ECF No. 18). See Gibson v. MGM International, No. 2:23-cv-00140-MMD- DIA,

(D. Nev. July 11, 2023). ITIS THEREFORE ORDERED that the stipulation (ECF No. 18) is GRANTED. The hearing 16 scheduled for December 16, 2025, is VACATED.

17|| IT IS FURTHER ORDERED that the parties must file a stipulated discovery plan and scheduling order either by March 27, 2026, or fourteen days after the Court rules on the pending motion to dismiss, whichever is earlier. 19 IT IS FURTHER ORDERED that the motion to stay discovery (ECF No. 16) is DENIED as 20 moot.

22 DANIEL J. ALBREGTS 23 UNITED STATES MAGISTRATE JUDGE 24 DATED: December 5, 2025 25 26 27

1 CERTIFICATE OF SERVICE 2 I, Dora Lane, declare: 3 I am employed in the City of Reno, County of Washoe, State of Nevada by Ascent Law, 4 P.C. My business address is 5470 Kietzke Lane, Ste. 300, Reno, NV 89511-2099. I am over the 5 age of 18 years and not a party to this action. 6 On December 3, 2025, I served the foregoing STIPULATION TO STAY DISCOVERY 7 AND VACATE HEARING ON DEFENDANT’S MOTION TO STAY DISCOVERY 8 PENDING MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by causing the 9 above-named document to be served via electronic service through the Court's CM ECF electronic 10 filing system, addressed as follows: 11 Erik Fitting, Esq. 12 2450 St Rose Pkwy, Ste 110 13 Henderson, NV 89074 [email protected] 14 15 I declare under penalty of perjury under the laws of the United States that the foregoing is 16 true and correct, and that this declaration was executed on December 3, 2025. 17 /s/Dora Lane 18 Dora Lane 19 20 21 22 23 24 25 26 27