1 | SAO CLARK SEEGMILLER, ESQ. 2 || Nevada Bar No. 3873 RICHARD HARRIS LAW FIRM 3

" Street Las Vegas, Nevada 89101 4 | Phone: (702) 444-4444 5 || Fax: (702) 444-4455 E-Mail: [email protected] 6 || Attorneys for Plaintiff 7 UNITED SATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 DELORES M. BLACK, individually, CASE NO.: 2:25-cv-02437-JAD-BNW 10 4 Plaintiffs, i2 1¥S-.

13 ||CPI-GREP AA I ALEXANDER, L.L.C. dba 14 [DESTINATIONS ALEXANDER, a Foreign Limited Liability Company; GREP 15 |SOUTHWEST, LLC a Foreign Limited Liability STIPULATION AND ORDER Company; GREYSTAR GLOBAL ENTERPRISE, TO AMEND COMPLAINT a Delaware Limited Liability Company; and 7 DOES I through X, inclusive 18 Defendants. 19 20 COMES NOW, Plaintiff DELORES M. BLACK, by and through her attorney of record 21 | CLARK SEEGMILLER, ESQ. of the RICHARD HARRIS LAW FIRM, and Defendants GREP 22 SOUTHWEST, LLC, by and through their counsel of record DAVID J. MARTIN, ESQ. of 23 GORDON REES SCULLY MANSUKHANL and pursuant to FRCP 13(a)(2) it is hereby stipulated 24 35 to allow Plaintiffs counsel to file a Second Amended Complaint to include all defendants named in 26 || the initial complaint. 27 ///

Page 1 of 3

1 A copy of the proposed Second Amended Complaint is attached hereto as Exhibit 1. 2 3 4 DATED: December 2025 DATED: December 23_, 2025

5 RICHARD HARRIS LAW FIRM GORDON REES SCULLY MANSUKHANI 6 /s/Clark Seegmiller /s/David Martin 7 | CLARK SEEGMILLER, ESQ. DAVID J. MARTIN, ESQ. g || Nevada Bar No.3873 Nevada Bar No. 9117 801 South Fourth Street . 300 South Fourth Street, Suite 1550 9 || Las Vegas, Nevada 89101 Las Vegas, Nevada 89101 Telephone: (702) 444-4444 Telephone: (916) 291-0779 10 | Facsimile: (702) 444-4455 [email protected] 1] || [email protected] Attorneys for Defendant Attorney for Plaintiff

13 ORDER 4 _ Pursuant to the stipulation entered into in this matter by all the parties, it is HEREBY 16 ORDERED that Plaintiff is granted leave to amend her Complaint pursuant to the Court’s order to

7 include all defendants named in the initial complaint. IT IS SO ORDERED.

18 Dated this 29thday of December, 2025.

21 hited States Magistrate Judge » DATED: December 29, 2025 23 24 25 26 27 28

Page 2 of 3

] 3 5 7 8 9 10 1] 12 13

15 (16

18 9 EXHIBIT 1 20 21 22 . 23 24 25 26 27 28

Page 3 of 3

1 | CLARK SEEGMILLER, ESQ. Nevada Bar No. 3873 2 || RICHARD HARRIS LAW FIRM 801 South Fourth Street 3 || Las Vegas, Nevada 89101 Phone: (702) 444-4444 4 | Fax: (702) 444-4455 || E-Mail: [email protected] Attorneys for Plaintiff 6 UNITED STATES DISTRICT COURT 7 g DISTRICT OF NEVADA g || DELORES M. BLACK, individually, CASE NO.: 2:25-cv-2437 10 Plaintiffs, 11 || vs. | CPEGREP AAT ALEXANDER, LLC. dba DESTINATIONS ALEXANDER, a Foreign 13 |] Limited Liability Company; GREP a SOUTHWEST, LLC, a Foreign Limited 14 | Liability Company; GREYSTAR GLOBAL SECOND AMENDED COMPLAINT ENTERPRISE, LLC, a Delaware Limited | Liability Company; and DOES I through X, inclusive. 16 17 Defendants. 18 COMES NOW PLAINTIFF DELORES M. BLACK, by and through her attorney of record, 19 || CLARK SEEGMILLER, ESQ. of the RICHARD HARRIS LAW FIRM, hereby complains and 29 || alleges as follows for her Second Amended Complaint: 7] GENERAL ALLEGATIONS 22 1. At all times mentioned, Plaintiff, DELORES M. BLACK, was and is a resident of 23 || the State of Nevada. 24 2. Plaintiff is informed and believes, and thereon alleges, that at all times relevant 25 || hereto, Defendant, CPI-GREP AA I ALEXANDER, L.L.C. dba DESTINATIONS ALEXANDER, 26 |! was and is a foreign limited-liability company doing business in Clark County, State of Nevada. 27 28

Page 1 of 6

3. Plaintiff ts informed and believes, and thereon alleges, that at all times relevar hereto, Defendant, GREP SOUTHWEST, LLC was and is a foreign limited-liability company doin; business in Clark County, State of Nevada. 5 4, Plaintiff is informed and believes, and thereon alleges, that at all times relevan 6 hereto, Defendant GREYSTAR GLOBAL ENTERPRISE, LLC was and is a Delaware limitec 7 liability company doing business in Clark County, State of Nevada. 8 5. All the facts and circumstances that give rise to the subject lawsuit occurred in Clark g || County, Nevada. 10 6. All the facts and circumstances that give rise to the subject lawsuit occurred on the 11 || property commonly known as Destinations Alexander located at 3949 West Alexander Road, North 12 || Las Vegas, NV, 89032 (“the Property”).

13 7. The true names of DOES | through X, their citizenship and capacities, whether 14 individual, corporate associate, partnership or otherwise, are unknown to Plaintiff who therefore 13 | sues these Defendants by such fictitious names. Plaintiff is informed and believes, and therefore 16 alleges, that each of the Defendants, designated as DOES I through X, are or may be, legally responsible for the events referred to in this action, and caused damages to the Plaintiff, as herein 18 alleged, and Plaintiff will ask leave of this Court to amend the Complaint to insert the true names and capacities of such Defendants, when the same have been ascertained, and to join them in this 20 action, together with the proper charges and allegations. 8. DOES I through ITT are employers of Defendants who may be liable for Defendants’ negligence pursuant to NRS 41.130, which states: 4 Except as otherwise provided in NRS 41.745, whenever any person shall suffer personal injury by wrongful act, neglect or default of another, the person causing the 25 injury is liable to the person injured for damages; and where the person causing the injury is employed by another person or corporation responsible for his conduct, that 6 person or corporation so responsible is liable to the person injured for damages. 7 9, DOES IV through X may be individuals or entities who owned, managed, operated, 2g || controlled, supervised, inspected, maintained, consulted, advised, furnished, repaired, cleaned

Page 2 of 6

and/or were responsible for the property and/or premises of as located at and/or in some other wa’ responsible for Plaintiff's damages. 10. Plaintiff is further informed and believes, and on that basis alleges, that certait 5 witnesses are known to Plaintiff as witnesses. However, Plaintiff does not yet know whether or no 6 particular witnesses have culpability in this matter at this time. However, once Plaintiff has 7 determined the true culpability of one or more of the DOE Defendants, Plaintiff will amen¢ g | Plaintiffs complaint to set forth facts and claims alleging the actual culpability and to substitute 9 || such witnesses for DOE Defendants. 10 11. At all times mentioned herein, Defendants, and each of them, were agents, servants, 1] || partners, employees or joint ventures of every other Defendants and/or DOE Defendants, and at ail 12 || times mentioned herein were acting within the course and scope of said agency, partnership, 13 employment, or joint venture, with knowledge, permission and consent of all said Defendants and/or | DOE Defendants and each of them, and in furtherance of the Defendants’ and/or DOE □□□□□□□□□□□ 15} business. 16 FACTUAL ALLEGATIONS 7 12. On or about January 7, 2024, Plaintiff, DELORES M. BLACK, was walking on the 18 premises of Destinations Alexander, when she tripped and fell on uneven pavement, 13. The fall caused Plaintiff to sustain serious injuries. 20 14, On or about January 7, 2024, Defendant, CPI-GREP AA I Alexander, L.L.C. dba DESTINATIONS ALEXANDER; GREP SOUTHWEST, LLC; GREYSTAR GLOBAL ENTERPRISE, LLC owned, controlled and/or maintained the Property located at 3949 West Alexander Road, North Las Vegas, NV, 89032. 95 FIRST CAUSE OF ACTION (Negligence) 26 15. Plaintiff repeats and realleges each and every allegation set forth above as though 27 each were set forth herein. 28

Page 3 of 6

16. On January 7, 2024, while at the property, Plaintiff tripped and fell over □□□□□ pavement and suffered serious injuries. 17. Defendants and/or DOE Defendants had a duty to keep the Property in a reasonably 5 safe condition for use. 6 18. Defendants and/or DOE Defendants breached their duty in that they failed to properly 4 design, construct, control, supervise, inspect, maintain, manage, operate, consult, advise, furnish. g || clean and/or repair the Property, thereby allowing a hazardous condition to exist which resulted in 9 | Plaintiff's injuries. 10 19. Defendants and/or DOE Defendants had a duty to warn persons, including Plaintiff, 11 about the unsafe condition on the Property and breached that duty by failing to warn of the uneven 12 || pavement. 13 20. Defendants’ and/or DOE Defendants’ actions and/or omissions violated specific 14 || Nevada statutes, regulations, and/or ordinances. 15 21. Plaintiff was and is a member of the class those statutes, regulations, and/or 16 ordinances were intended to protect and exist to protect. 22. Defendants’ and/or DOE Defendants’ actions and/or omissions in violation of these 8 statutes, regulations, and/or ordinances proximately actually caused Plaintiffs fall and resulting 19 injuries at issue here. *0 23. Defendants’ and/or DOE Defendants’ negligence was the actual and proximate cause of the injuries incurred by Plaintiff, resulting in medical expenses, permanent injury, lost wages, and pain and suffering in an amount in excess of $15,000. 24, It has been necessary for Plaintiff to retain the services of counsel to represent her in 25 the above-entitled matter, and she should be awarded reasonable attorneys’ fees and costs of suit 6 incurred herein. 47 ag iii

Page 4 of 6

I PRAYER FOR RELIEF 2 Wherefore, Plaintiff prays for relief and judgment as against Defendants as follows: 3 4 1. Compensatory damages in excess of $15,000, according to proof at trial; 2. Interest from the time of service of this complaint as allowed by NRS 17.130; 5 3. Costs of suit and attorney fees; and 6 4, For such other and further relief as the court may deem appropriate. 7 3 DATED: December 23, 2025, 9 RICHARD HARRIS LAW FIRM 10 . /s/ Clark Seegmiller, Esq. 11 Clark Seegmiller, Esq. Nevada Bar No. 3873 12 801 So. Fourth Street Las Vegas, Nevada 89101 13 Attorney for Plaintiffs

14 15 16 17 18 19 20 2] 22 23 24 25 26 27 28

Page 5 of 6

| CERTIFICATE OF E-SERVICE 2 Pursuant to Fed. R. Civ. P. 5 and LR 5-1, I certify that I am an employee of the □□□□□□□ 4 HARRIS LAW FIRM, and that on this 19% day of December 2025, I served a copy of the SECON] 5 | AMENDED COMPLAINT as follows: 6 U.S. Mail: By depositing a true and correct copy of said document(s) via U.S. mail, 7 ith postage pre-paid and addressed as listed below. 8 | Oana Delivery: I caused said document(s) to be delivered to the address(es) list below; 9 lectronic Mail: I caused said document(s) to be delivered by emailing an attached 10 Adobe Acrobat PDF of the document to the email address(es) identified above. u Electronic Service: I caused said document to be delivered by electronic means upon 12 all eligible electronic recipients via the United States District Court CM/ECF system 4 or Clark County District Court E-Filing system (Odyssey).

| DAVIDI. MARTIN, FSO, Nevada Bar No, 9117 15 || MYRRAL. SMITH, ESQ. Nevada Bar No. 15539 16 | GoRDON REES SCULLY MANSUKHANI LLP 17 | 300 South 4th Street, Suite 1550 Las Vegas, Nevada 89101 18 || [email protected] 19 [email protected] 20 21 /s/Amanda Frizzell eee 23 An employee of RICHARD HARRIS LAW FIRM 24 25 26 27 28

Page 6 of 6