JUDITH ROSS, as an individual v. THE HOME DEPOT, INC., a foreign corporation;...

1 GRIFFITH H. HAYES Nevada Bar No. 7374 MICHAEL MCLOUGHLIN Nevada Bar No. 12820 Email(s): [email protected] [email protected] 2835 St. Rose Pkwy., Suite 140 Henderson, NV 89052 Telephone: (702) 724-2648 Facsimile: (702) 410-7684 Attorneys for Defendant KRG Las Vegas Centennial Center, LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA JUDITH ROSS, as an individual, Case No. 2:25-cv-00931 12 Plaintiff, STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES 13 v. (SECOND REQUEST) THE HOME DEPOT, INC., a foreign corporation; HOME DEPOT U.S.A. INC. d/b/a THE HOME DEPOT, a foreign corporation; HOME DEPOT MANAGEMENT COMPANY, LLC d/b/a THE HOME DEPOT, a foreign limited- liability company; KRG LAS VEGAS CENTENNIAL CENTER, LLC; a foreign limited-liability company; DOES I-X; and ROE CORPORATIONS I-X, inclusive Defendants.

22 IT IS HEREBY STIPULATED AND AGREED, between the parties and their attorneys of record, that the current discovery deadlines to be extended as indicated on page 4, pursuant to Local Rule 26-1(b) and 26-3. This is the second stipulation for extension of discovery deadlines.

25 I.

26 DISCOVERY COMPLETED TO DATE 27 1. The parties have conducted the FRCP 26.1 Early Case Conference.

28 2. Plaintiff produced her Initial Disclosure on July 9, 2025.

2 2025 (responses served on September 15, 2025).

3 4. Defendant Home Depot produced its Lists of Witnesses and Documents on August 5, 2025.

5 5. Defendant KRG Las Vegas Centennial Center, LLC produced its Lists of Witnesses and Documents on September 12, 2025.

7 6. Defendant KRG Las Vegas Centennial Center, LLC propounded its First Set of Interrogatories (25 Interrogatories), Requests for Production of Documents (32 Requests), and Requests for Admissions (26 Requests) to Plaintiff on August 5, 2025.

10 7. Plaintiff propounded her First Set of Interrogatories (20 Interrogatories), Requests for Production of Documents (37 Requests) to Defendant KRG Las Vegas Centennial Center, LLC on October 3, 2025.

13 8. Plaintiff provider her responses to Defendant KRG Las Vegas Centennial Center, LLC’s Interrogatories (25 Interrogatories), Requests for Production of Documents (32 Requests), and Requests for Admissions (26 Requests).

16 9. Plaintiff produced her first Supplement to her Initial Disclosure on September 15, 2025.

18 10. Plaintiff produced her Second Supplement to her Initial Disclosure on September 25, 2025.

20 11. Defendant KRG Las Vegas Centennial Center, LLC provided its responses to Plaintiff’s First Set of Interrogatories (20 Interrogatories), Requests for Production of Documents (37 Requests) on December 10, 2025.

23 12. Defendant KRG Las Vegas Centennial Center, LLC provided its First Supplement to its Lists of Witnesses and Documents on December 10, 2025.

25 13. Site inspection was conducted on October 27, 2025.

26 /// /// /// 2 DISCOVERY THAT REMAINS TO BE COMPLETED 3 1. Rule 35 Examination of Plaintiff.

4 2. Deposition of Defendant KRG Las Vegas Centennial Center, LLC’s 30(b)(6) 5 witness(es).

6 3. Deposition of Plaintiff.

7 4. Deposition of Defendant The Home Depot, Inc.’s 30(b)(6) witness(es).

8 5. Deposition of Defendant Home Depot U.S.A. Inc. d/b/a The Home Depot’s 9 30(b)(6) witness(es).

10 6. Deposition of Defendant Home Depot Management Company d/b/a The Home 11 Depot’s 30(b)(6) witness(es).

12 7. Designation of Initial Experts.

13 8. Designation of Rebuttal Experts.

14 9. Deposition(s) of Plaintiff’s treating physicians.

15 10. Deposition of other percipient witnesses.

16 11. Depositions of experts.

17 12. Additional written discovery (if necessary).

18 13. Any remaining discovery the parties deem relevant and necessary as discovery 19 continues.

20 III.

21 WHY DISCOVERY CANNOT BE COMPLETED WITHIN THE TIME PROVIDED BY 22 THE CURRENT SCHEDULING ORDER 23 A. Good Cause 24 LR 26-3 governs modifications or extension of the Discovery Plan and Scheduling Order.

25 Any stipulation or motion to extend or modify that Discovery Plan and Scheduling Order must be made no later than twenty-one (21) days before the expiration of the subject deadline and must comply fully with LR 26-3. If the stipulation is made less than twenty-one (21) days before the expiration of a deadline, the parties must show a good cause exist. A request made after the the failure to act was the result of excusable neglect.

3 A request to extend unexpired deadlines in the scheduling order must be premised on a showing of good cause. Fed. R. Civ. P. 16(b)(4); Local Rule 26-3. The good cause analysis turns on whether the subject deadlines cannot reasonably be met despite the exercise of diligence.

6 Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992).

7 Good cause exists for the following reasons: Defendants KRG and Home Depot entities are currently attempting to resolve tender issues prior to incurring experts’ expenses.

9 Plaintiff has recently suffered the loss of her husband which temporarily affected her ability to participate to this litigation. The parties are diligently working on coordinating her deposition and Rule 35 Examination.

12 The parties agree to extend all the current discovery deadlines by 45 days subject to the approval of this court.

14 IV.

15 PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY 16 Discovery Deadline Current Deadline Proposed Deadline Motion to Amend/Add Parties Closed Closed Initial Expert Disclosures January 26,2026 March 12, 2026 All Rebuttal Expert Disclosures February 24, 2026 April 10, 2026 Discovery Cut-Off Date March 26, 2026 May 11, 2026 Dispositive Motions April 27, 2026 June 11, 2026 Pretrial Order May 28, 2026 July 13, 2026 /// /// /// /// /// /// /// ] The parties represent this Stipulation is sought in good faith and with excusable neglect || and not interposed for delay or any other improper purpose.

3 || Dated this 20 day of January, 2026. Dated this 20" day of January, 2026.

4 | TYSON & MENDES LLP HENNESS & HAIGHT || /s/ Griffith Hayes /s/ Jacob Smith 6 _ GRIFFITH H. HAYES JACOB S. SMITH || Nevada Bar No. 7374 Nevada Bar No. 10231 g MICHAEL MCLOUGHLIN 8972 Spanish Ridge Avenue Nevada Bar No. 12820 Las Vegas, Nevada 89148 g || 2835 St. Rose Pkwy., Suite 140 Attorneys for Plaintiff Henderson, NV 89052 || Attorneys for Defendant KRG Las Vegas Centennial Center, LLC D Dated this 20" day of January, 2026.

B HALL HERNANDEZ SMITH || /s/ Kevin Smith | MICHAEL R. HALL Nevada Bar No. 5978 || KEVIN S. SMITH 17 Nevada Bar No. 7184 7425 Peak Drive || Las Vegas, Nevada 89128 Attorneys for Defendants The Home Depot, || Inc., Home Depot U.S.A. Inc. d/b/a The Home Depot, and Home Depot Management 20 Company d/b/a The Home Depot 23 IT IS SO ORDERED.

24 .

UNITED STATES MAGISTRATE JUDGE

Kellene Fletcher From: Jake Smith <[email protected]> Sent: Tuesday, January 20, 2026 8:15 AM To: Richard Verlander; Kevin Smith Ce: [email protected]; Griffith Hayes; Stefania Rota Scalabrini; Kellene Fletcher; Jody Foote; lona Shepard; Vanessa Anderson; Yvonne Giraud; Mike Hall Subject: RE: Ross v. KRG & Home Depot. / Case No. 2:25-cv-00931-ART-DJA (25-2399) site inspection was conducted on October 27, 2025. We should include that in the discovery completed and remove it from the to be completed. With those revisions you can affix my signature and submit.

JACOB S. SMITH Henness & Haight Injury Law 8972 Spanish Ridge Avenue, Las Vegas, Nevada 89148 702-862-8200 | Fax: 702-862-8204 From: Richard Verlander <[email protected]> Sent: Tuesday, January 20, 2026 7:26 AM Kevin Smith <[email protected]>; Jake Smith <[email protected]>; James Longbrake <[email protected]> Cc: [email protected]; Griffith Hayes <[email protected]>; Stefania Rota Scalabrini <[email protected]>; Kellene Fletcher <[email protected]>; Jody Foote <[email protected]>; lona Shepard <[email protected]>; Vanessa Anderson <[email protected]>; Yvonne Giraud <[email protected]>; Mike Hall <[email protected]> Subject: RE: Ross v. KRG & Home Depot. / Case No. 2:25-cv-00931-ART-DJA (25-2399) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Kevin.

Richard Verlander Senior Counsel 2835 St. Rose Parkway, Suite 140 Henderson, Nevada 89052 Phone: 702.724.2648 Direct: 725.238.2516 Fax: 702.410.7684 [email protected] _ www.tysonmendes.com F = I Mansfielc 7 if a ay. Certified 2024- This email and any attachments are from the law firm of Tyson & Mendes, LLP. This email is intended only for the use of the addressee and may contain information that is proprietary, confidential, privileged, or protected by state or federal law. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this email and attachments are If you received this email in error, please notify us by reply email immediately so we may arrange for the retrieval of the information.

From: Kevin Smith <[email protected]> Sent: Tuesday, January 20, 2026 9:24 AM Richard Verlander <[email protected]>; Jake Smith <[email protected]>; James Longbrake <[email protected]> Cc: [email protected]; Griffith Hayes <[email protected]>; Stefania Rota Scalabrini <[email protected]>; Kellene Fletcher <[email protected]>; Jody Foote <[email protected]>; lona Shepard <[email protected]>; Vanessa Anderson <[email protected]>; Yvonne Giraud <[email protected]>; Mike Hall <[email protected]> Subject: RE: Ross v. KRG & Home Depot. / Case No. 2:25-cv-00931-ART-DJA (25-2399) is fine. You can sign electronically for me on behalf of Home Depot.

Kevin S. Smith, Esq.

HALL!HERNANDEZ SMITH ATTORSETS AT LAW HALL HERNANDEZ SMITH 7425 Peak Drive, Suite 100 Las Vegas, NV 89128 Phone: (702) 316-4111 Fax: (702) 316-4114 Email: [email protected] From: Richard Verlander <[email protected]> Sent: Monday, January 19, 2026 2:00 PM Jake Smith <[email protected]>; Kevin Smith <[email protected]>; James Longbrake <[email protected]> Cc: [email protected]; Griffith Hayes <[email protected]>; Stefania Rota Scalabrini <[email protected]>; Kellene Fletcher <[email protected]>; Jody Foote <[email protected]>; lona Shepard <[email protected]>; Vanessa Anderson <[email protected]>; Yvonne Giraud <[email protected]>; Mike Hall <[email protected]> Subject: RE: Ross v. KRG & Home Depot. / Case No. 2:25-cv-00931-ART-DJA (25-2399)