Shamika Abdelkader v. Best Buy Co, Inc.; Bestbuy.com LLC; Best Buy Stores, L.P.

1 JNaecvka Pd.a BSutartdee nB,a Er sNqo. . 6918 Jamie L. Clark, Esq.

Nevada State Bar No. 16687 BACKUS | BURDEN 3050 South Durango Drive Las Vegas, NV 89117 (702)872-5555 (702)872-5545 [email protected] [email protected] Attorneys for Defendants Best Buy Co, Inc. Bestbuy.com LLC Best Buy Stores, L.P. 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA SHAMIKA ABDELKADER, ) 13 ) Case No. 2:25-cv-01268-JAD-DJA Plaintiffs, ) 14 vs. ) ) STIPULATION AND ORDER TO HP INC., a Delaware Corporation; BEST ) EXTEND DISCOVERY DEADLINES BUY CO., INC., a Delaware Corporation; ) BESTBUY.COM, LLC, a Delaware Limited ) First Request Liability Company; BEST BUY STORES, ) L.P., a Delaware Limited Partnership; and ) DOES 1-10, inclusive, and ROE ) CORPORATIONS 1-10, inclusive. ) ) 20 Defendants ) 21 In accordance with Local Rules of Practice for the United States District Court for the 26-3 District of Nevada (“LR”) 26-4, Plaintiff SHAMIKA ABDELKADER, by and through her counsel of record, Noah Duran, Esq. of the law firm of Ryan Alexender, Chtd. (“Plaintiff”), Defendant/Cross-Defendant HP INC., by a. through its counsel of record, Edgar Carranza, Esq. the law firm of Messner Reeves LLP, and Defendants/Cross-Claimants BEST BUY CO., INC., BESTBUY.COM, LLC, and BEST BUY STORES, L.P., by and through its counsel Jack Burden, Esq. of the law firm Backus | Burden (collectively “Best Buy”), hereby stipulate and agree to an extension of all discovery deadlines by sixty (60) days. The parties propose the following revised discovery plan: Pursuant to Local Rule 6-1(b), the Parties hereby aver that this is the first such discovery extension requested in this matter. Moreover, 1) there is no danger of prejudice as the extension is stipulated by the Parties; 2) a sixty (60) day extension will not impact a trial date because the same has not been scheduled; 3) the Parties, their respective Counsel, and witnesses have been limited in appearing for deposition due to the recent holiday season; and 4) the requested extension is made in good faith by both Parties. Pioneer Investment Services v. Brunswick Associate’s, Ltd., 507 U.S. 380, 395 (1993).

I.

12 DISCOVERY COMPLETED TO DATE 13 Discovery completed includes: 14 1. Plaintiff served her Initial Disclosure Pursuant to FRCP 26 on September 18, 2025; 2. Best Buy served its Initial Disclosure Pursuant to FRCP 26 on September 25, 2025; 3. HP Inc. served its Initial Disclosure Pursuant to FRCP 26 on October 3, 2025; and 4. HP Inc. served its First Set of Interrogatories and Requests for Production to Plaintiff on December 31, 2025.

20 II.

DISCOVERY TO BE COMPLETED AND REASONS 21 FOR EXTENSION OF DISCOVERY 22 Discovery to be completed includes: 1. Supplementation of the Parties FRCP 26 Initial Disclosures.

2. Plaintiff’s service of responses to HP Inc.’s First Set of Interrogatories and Requests for Production.

3. [Potential] Testing of the subject laptop / battery.

28 4. Rule 35 Examination of Plaintiff.

1 5. Deposition of Plaintiff.

2 6. Depositions of fact witnesses.

7. Depositions of Plaintiff’s treating medical providers.

8. Depositions of Defendants’ employees.

9. Deposition of Defendants’ FRCP 30(b)(6) representative(s).

10. FRCP 26(a)(2) designation of initial and rebuttal expert witnesses.

8 11. Depositions of initial and rebuttal expert witnesses.

9 Additional written discovery and depositions as the Parties deem necessary.

10 The Parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested extension.

III.

13 REASONS WHY DISCOVERY WAS NOT COMPLETED WITHIN TIME SET BY DISCOVERY PLAN Plaintiff filed her Complaint on June 21, 2025. HP Inc. filed its Removal on Jule 14, 2025.

16 Since that time, Best Buy Answered Plaintiff’s Complaint and filed a Crossclaim against HP Inc. Due to the holidays, the parties were not able to complete written discovery and/or conduct factual / percipient depositions. As such, the parties agree to extend discovery deadlines for sixty (60) days.

The parties have entered into this agreement in good faith and not for purposes of delay.

IV.

21 DISCOVERY DEADLINES 22 Discovery cutoff: March 25, 2026 Amending the pleadings or adding parties: December 26, 2026 Initial expert disclosures: January 26, 2026 Rebuttal expert disclosures: February 23, 2026 Dispositive motions: April 24, 2026 28 Joint Pre-Trial Order, if no Dispositive Motions: May 26, 2026 1 CASE NO.: 2:25-cv-01268-JAD-DJA Abdelkader v. HP, Inc., et al.

2 Stipulation and Order to Extend (First Request) 3 Vil. [PROPOSED] NEW DISCOVERY DEADLINES 5 Discovery cutoff: May 25, 2026 6 Amending the pleadings or adding parties: Closed 7 Expert disclosures: March 27, 2026 8 Rebuttal expert disclosures April 27, 2026 ? Dispositive motions: June 24, 2026 Joint Pre-Trial Order, if no Dispositive Motions: July 27, 2026 + The Parties aver that this request for extension of discovery deadlines is made by the B Parties in good faith and not for the purpose of delay.

g 2141 DATED this _20thday of Jan., 2026. DATED this 16th day of Jan., 2026.

EZ 15 || RYAN ALEXANDER, CHTD. BACKUS | BURDEN 16 || _4s/Noah A. Duran /s/Jamie L, Clark a NOAH A. DURAN, ESQ. JACK P. BURDEN, ESQ.

Nevada Bar No. 15033 Nevada Bar No. 6918 = 18 3017 West Charleston Blvd., Ste. 10 JAMIE L. CLARK, ESQ. = Las Vegas, Nevada 89102 Nevada State Bar No. 16687 || Attorneys for Plaintiff 3050 South Durango Drive Las Vegas, Nevada 89117 || DATED this 20th day of Jan., 2026. Attorneys for Best Buy Co, Inc. MESSNER REEVES, LLP Bestbuy.com LLC 21 Best Buy Stores, L.P. /s/Edgar Carranza EDGAR CARRANZA, ESQ.

23 || Nevada Bar No. 5902 TIFFANIE BITTLE, ESQ.

24 || Nevada Bar No. 15179 8945 West Russell Rod, Sute 300 25] Las Vegas, Nevada 89148 Attorneys for HP Inc. ORDER 27 IT IS SO ORDERED. ) O .

DATED: 1/21/2026 <A U UNITED STATES\MAGISTRATE JUDGE