Rachel Chua, individually and on behalf of all others similarly situated v....

Robert L. Rosenthal, Esq.

1! Nevada Bar. No. 6476 || John J. Savage, Esq. ~ || Nevada Bar. No. 11455 HOWARD & HOWARD ATTORNEYS PLLC 3800 Howard Hughes Parkway, Suite 1000 Las Vegas, Nevada 89169 Telephone: (702) 257-1483 ~ || E-Mail Address: [email protected] 6 [email protected] || Matthew S. Disbrow, Esq.

California State Bar No. 294764 || HONIGMAN LLP 2290 First National Building ? II Detroit, Michigan 48226 || Telephone: (313) 465-7000 E-Mail Address: [email protected] || Pro Hae Vice Application Forthcoming Attorneys for Neuromonitoring Associates, LLC 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA || RACHEL CHUA, individually and on behalf of | Case No.: 2:25-cv-02266-JCM-MDC all others similarly situated, 16 Plaintiff STIPULATION AND ORDER TO STAY 7 , ALL DEADLINES AND PROVIDE LIMITED EQUITABLE TOLLING NEUROMONITORING ASSOCIATES, LLC, | (Action filed on November 17, 2025) 20 Defendants.

29 Plaintiff Rachel Chua (‘Plaintiff’) and Defendant Neuromonitoring Associates, LLC || ((NMA”) (together, the Parties), by and through undersigned counsel, hereby stipulate as follows: 24 1. All current case deadlines are stayed pending the Court’s decision on Defendant’s Motion to Dismiss for Lack of Personal Jurisdiction and Venue or, Alternatively, to Compel Arbitration, filed on December 12, 2025 (the “Motion”). This stay includes the Federal Rule of Civil Procedur 26(f) conference, any related discovery plan and scheduling order deadlines, and all discovery an motion deadlines otherwise applicable during the pendency of the Motion. No stay applies beyond the > point of the Court’s decision on the pending Motion absent further agreement of the Parties or order 6 || the Court.

4 a The statute of limitations applicable to Fair Labor Standards Act claims of putative > || collective members in this action is tolled only trom the date this Order is entered until the date th Court issues its ruling on the Motion. No tolling applies beyond that point absent further agreement o the Parties or order of the Court. This stipulated tolling applies only to putative collective members’ FLSA claims asserted in this action against Defendant. Plaintiff reserves the right to seek additional || tolling in this matter, which is not part of this stipulation, and Defendant reserves all rights and defense || regarding any such request for additional tolling.

12 3. This stipulation does not constitute an admission by any party regarding any issue, including those pertaining to the pending Motion, All parties preserve all claims, defenses, objections, and arguments of the Parties, including as to arbitrability, collective certification, merits, and damages, 4, If necessary, within 14 days after the Court issues its ruling on the Motion, the Partie will meet and confer and submit either a proposed discovery plan and scheduling order under Rule 26( || Or a joint status report advising the Court of proposed next steps consistent with the ruling.

19 5. The Parties agree that good cause exists for the stay and limited tolling set forth herei II to promote judicial economy and avoid unnecessary expense while the Motion is pending.

i 6. On this 12 day of January, 2026, the Parties respectfully request that the Court ente the Order.

3 IT IS SO STIPULATED, 411 Dated: January 12, 2026 Attorneys for Plaintiff Attorneys for Defendant By: /s/ Anna Prakash By: _ 4s/ Robert L. Rosenthal 7 Robert L. Rosenthal, Esq.

8 LEAH L. JONES Nevada Bar. No. 6476 Nevada State Bar No. 13161 HOWARD & HOWARD ATTORNEYS PLLC 9 JOSHUA D. BUCK 3800 Howard Hughes Parkway, Suite 1000 Nevada State Bar No, 12187 Las Vegas, Nevada 89169 10 THIERMAN BUCK LAW FIRM Telephone: (702) 257-1483 W. Liberty Street E-Mail Address: [email protected] 1] Reno, NV 89501 Matthew S. Disbrow, Esq.

Tel: 775.284.1500 California State Bar No. 294764 12 Fax: 775.703.5027 HONIGMAN LLP 13 {eal thiennanbuekeom 2290 First National Building [email protected] Detroit, Michigan 48226 15 ANNA PRAKASH, MN No,'035 1362 Pro Hac Vice Application Forthcoming CAITLIN OPPERMAN, MN No. 0399978 16 NICHOLS KASTER, PLLP 80 South 8" Street 17 4700 IDS Center Minneapolis, MN 55402 Tel: 612.256.3200 Fax: 612.338.4878 [email protected] 20 [email protected] [email protected] 2] Admitted Pro Hac Vice 22 ORDER ||Future filings must be filed in searchable IT IS SO ORDERED: pdf. format per LR IA 10-1(b). Filings OA o~ |}which do not comply with LR IA 10-1(b) poy) may be denied or rejected. got fi f- 26 Hon, jaaximi ye od DCouvillier, IT 97 United States’ apistrate Judge DATED: January 15, 2026