1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Angela Williams, et al., Case No. 2:21-cv-01676-APG-MDC 4 Plaintiffs, ORDER ON DISCOVERY DISPUE 5 vs. STIPULATIONS (ECF NOS. 340 AND 341) and COMPELLING DISCOERY 6 Jamal Rashid, et al., RESPONSES FROM JANE DOE #1 7 Defendants. 8 9 10 Pending before the Court are the Stipulations Regarding Discovery Dispute (ECF Nos. 340 and 11 341) filed unilaterally by defendants Western Best, Inc. (“Western Inc.”) and Western Best, LLC 12 (“Western, LLC) in compliance with the Court’s 8/16/2024 Standing Order (ECF No. 217). For the 13 reasons stated below, the Court GRANTS the stipulations and compels plaintiff Jane Doe #1 to fully 14 and without objections respond by January 9, 2026, to the interrogatories served by Western Inc. and 15 Western, LLC as set forth in this order. 16 The Court further orders Jane Doe #1 to show cause, in writing, by January 23, 2026, why her 17 or her counsel should not be sanctioned for failing to comply with the Court’s 8/16/2024 Standing 18 Order. 19 DISCUSSION 20 This case arises from alleged sex trafficking of plaintiffs by defendants. See ECF No. 49. To 21 resolve discovery disputes more effectively and expeditiously, the Court entered its 08/16/2024 Standing 22 Order (ECF No. 217). Among other things, the Standing Order sets forth the process for resolving 23 discovery disputes, which requires the parties to file a Stipulation Regarding Discovery Dispute in 24 which they present their dispute, and their respective positions as follows:

25 1 B. Discovery Disputes 1 Pursuant to LR 1-1(b)(2), Judge Couvillier requires the parties to follow 2 the procedures outlined below regarding any discovery dispute. No discovery motion may be filed until the following procedure has been 3 followed and such motion is ordered by Judge Couvillier: 4 1. If a discovery dispute arises the parties must first meet and confer to try to resolve their dispute in compliance with LR IA 1-3(f). 5 Lead counsel for each party shall meet and confer in person, videoconference, or telephone. A mere exchange of letters or e-mails does 6 not satisfy the meet and confer requirement. 2. If the parties are unable to resolve their dispute informally after 7 a good-faith effort, the parties must file a single document captioned “Stipulation Regarding Discovery Dispute” that addresses each one of the 8 following items: i. A brief, joint summary of the discovery dispute not to exceed 9 one (1) page; 10 ii. A restatement of the full text of the discovery requests, or deposition question, in dispute as originally stated and the 11 responses to the requests. This may be done in single-spaced, 10- font. 12 ii. A joint summary of the meet-and-confer efforts as required by LR IA 1-3(f), which includes: (1) a summary of discussions; (2) 13 identification of time, place, manner, and participants; and (3) certification from counsel that, despite a sincere effort, the parties 14 were unable to resolve or narrow the dispute without court intervention. This joint meet-and-confer summary may not exceed 15 two (2) pages. iii. An explanation, without boilerplate language, of the position 16 taken by each side, not to exceed two (2) pages per side. 17 v. Each side must make a proposal of compromise or resolution of the disputed discovery (e.g., request, interrogatory, deposition 18 question). The proposal may not exceed two (2) pages per side. 19 Id. 20 Pursuant to the Court’s Standing Order, defendants Western Inc. and Western LLC filed their 21 respective Stipulations Regarding Discovery Dispute (ECF Nos. 340 and 341) regarding disputes over 22 plaintiff Jane Doe #1’s responses to defendants’ interrogatories. Defendants filed their stipulations 23 unilaterally because Jane Doe #1’s counsel refused to join in the preparation and submission of the 24 stipulations. Jane Doe #1 also elected not respond to the stipulations. 25 // 2 1 DISCOVERY AT ISSUE 2 The discovery at issue concerns defendant Western Inc.’s First Set of Interrogatories to plaintiff 3 Jane Doe #1 and defendant Western LLC’s First and Second Sets of Interrogatories to plaintiff Jane Doe 4 #1. Jane Doe #1 responded to defendants’ interrogatories on March 6, 2025. Defendants argue that Jane 5 Doe #1’s interrogatory responses are deficient, incomplete, and evasive. ECF Nos. 340 and 341. 6 Defendants also challenge the merits of Jane Doe #1’s objections to the interrogatories. Id. According 7 to defendants, they made numerous meet and confer efforts with Jane Doe #1 to resolve their discovery 8 disputes. Jane Doe #1 eventually agreed to supplement her responses but failed to do so. 9 On November 3, 2025, counsel for Western Inc. and Western LLC sent counsel for Jane Doe #1 10 drafts of their stipulations (ECF Nos. 340 and 341) and requested her counsel to draft plaintiff’s portion 11 of the stipulation and make any other additions. Defendants afforded Jane Doe #1’s counsel reasonable 12 time and opportunity to prepare plaintiff’s requisite sections of the stipulations. Jane Doe #1, however, 13 failed to provide defendants with her requisite sections or otherwise cooperate in the process. ECF Nos. 14 340 and 341. Thus, defendants filed their stipulations unilaterally on November 25, 2025. ECF Nos. 15 340 and 341. Jane Doe #1 also elected not respond to the defendants’ stipulations or otherwise dispute 16 the arguments or representations made by defendants therein. The Court construes Jane Doe #1’s failure 17 to respond as her consent to the relief requested by the stipulations and to the merits of defendants’ 18 arguments and assertions. See LR 7-2(d); Warren v. Dollar Tree, No. 23-CV-01377-APG-EJY, 2023

, at *2 (D. Nev. Oct. 31, 2023) (“The District of Nevada Local Rule 7-2(d) applies not only 20 to an opposing party's failure to file a physical document, but also to failure to assert in an opposition 21 arguments that oppose those presented in the motion.”); Mortg. Fund IVC Tr. 2016-RN5 v. Brown, No. 22 2:17-CV-2309-KJD-BNW,

, at *2 (D. Nev. Jan. 21, 2021) (“[T]he Court interprets 23 Defendant's failure to respond to Plaintiff's arguments as an admission of the motion's merit and as 24 25 3 1 consent to granting the motion.”), aff'd sub nom. Linear Mortg., LLC v. Saticoy Bay LLC Series 2175 2 Clearwater Lake, No. 21-15294,

(9th Cir. Apr. 29, 2022). 3 SHOW CAUSE 4 Jane Doe #1 violated the Court’s 08/16/2024 Standing Order (ECF No. 217). Under Fed. R. Civ.

(f)(1)(C), the Court may impose any “just” sanctions if a party or its attorney fails to obey a pretrial 6 order. A finding of bad faith under Rule 16 is not required. Sanctions per Rule 16 may be imposed even 7 when disobedience is unintentional. See Lucas Auto. Eng'g, Inc. v. Bridgestone/Firestone, Inc., 275

, 769 (9th Cir. 2001). The Court may also impose “any and all appropriate” sanctions under 9 Local Rule IA 11-8.

Finally, the Court may impose sanctions pursuant to its inherent powers. See 10 Chambers v. NASCO, Inc.,

, 48 n.13 (1991) (there is no indication in Rule 16 “of an intent to 11 displace the inherent power, but rather simply to provide courts with an additional tool by which to 12 control the judicial process.”). Such sanctions include reasonable fees and costs for failing to comply 13 with a magistrate judge’s pre-trial orders. CLM Partners LLC v. Fiesta Palms, LLC, No. 2:11-cv- 14 01387-PMP-CWH,

(D. Nev. Dec. 5, 2013). 15 Therefore, the Court orders plaintiff Jane Doe #1 to show cause why she or her counsel should 16 not be sanctioned for failing to comply with the Court’s 08/16/2024 Standing Order (ECF No. 217). 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 4 1 ORDER 2 For the foregoing reasons: 3 IT IS ORDERED that: 4 1. Western Inc.’s Stipulation Regarding Discovery Dispute (ECF No. 340) is GRANTED. 5 Plaintiff Jane Doe #1 shall serve by January 9, 2026, full, complete, and comprehensive 6 responses, without any objections, to Western Inc.’s First Set of Interrogatories. 4 2. Western LLC’s Stipulation Regarding Discovery Dispute (ECF No. 341) is GRANTED.

Plaintiff Jane Doe #1 shall serve by January 9, 2026, full, complete, and comprehensive responses, without any objections, to Western LLC’s First Set of Interrogatories and Second Set of Interrogatories. 3. Plaintiff Jane Doe #1 is ordered to show cause, if any, by no later than January 23, 2026, why she or her counsel should not be sanctioned for failing to comply with the Court’s 08/16/2024 Standing Order (ECF No. 217). DATED: December 11, 2025. 4 IT IS SO ORDERED.

Hos/Maximiliano | . CeAivillier, III 17 Yrlited States/Magistrate Judge jp 19 20 21 22 23 24 25