Jazlene Baez, Individually and on Behalf of All Others Similarly Situated v. L Ibra, LLC

Opinion

Nevada Bar No. 6170 CAMI M. PERKINS, ESQ. Nevada Bar No. 9149 CLARK HILL PLLC 1700 South Pavilion Center Drive, Suite 500 Las Vegas, Nevada 89135 Telephone:(702) 697-7545 Facsimile: (702)862-8400 nwieczorek@clarkhill.com cmperkins@clarkhill.com Attorneys for Defendant L IBRA, LLC UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA Case No.: 2:24-cv-02096-JAD-EJY JAZLENE BAEZ, Individually and on Behalf of All Others Similarly Situated, STIPULATION AND ORDER TO EXTEND Plaintiffs, PROPOSED JOINT PRETRIAL ORDER DEADLINE v. (FIRST REQUEST) Defendant. Defendant Libra, LLC (“Libra”), by and through its counsel Nicholas M. Wieczorek, Esq., Cami M. Perkins, Esq., of the law firm Clark Hill PLLC, hereby stipulate to extend the pre-trial order deadline for a period of sixty (60) days. Counsel for plaintiff and defendant have been in settlement discussions for approximately three weeks. Ongoing settlement discussions may lead to the resolution of this case. Further, the parties stipulated for additional discovery and fact finding which needs to be completed within the extended compliance period. Final discovery in this matter was delayed due to defense counsel’s recent substitution into the case in late December, 2025, which resulted in minimal delays occasioned by the transition of defense counsel. The parties intend to continue to negotiate in good faith during the extended time period before filing the pretrial order with a goal of reaching settlement of the case. District courts have inherent power to control their dockets, including any requests by the parties to continue an existing trial setting (Hamilton Copper & Steel Corp., v. Primary Steel, Inc., 898 F.2d 1428, 1429 (9th Cir. 1990); Oliva v. Sullivan, 958 F.2d 272, 273 9th Cir. 1992)). A motion for continuance of trial should be granted for good cause (Fed.R.Civ.P. 16(b)(4). The trial court has discretion as to what constitutes good cause (See U.S. v. Makley, 468 F.2d 916, 917 (9th Cir. 1972)). The good-cause standard is met where a deadline cannot be met despite the moving party’s diligence (Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)). In determining whether to grant a continuance of a trial date, the Court considers four factors: (1) the movant’s diligence in preparing for the date set for trial; (2) the likelihood that a continuance will address the need giving rise to the motion for a continuance; (3) the extent to which a continuance will inconvenience the court and the opposing party, including its witnesses; and (4) whether the movant will suffer prejudice if the continuance is denied (United States v. Flynt, 756 F.2d 1352, 1358 (9th Cir.), amended, 764 / / F.2d 675 (9th Cir. 1985)). The weight attributed to any single factor may vary with the extent of the showings on the other factors. The parties anticipate being able to conclude all settlement negotiations, factual investigation and other efforts to achieve case resolution within the extended time period. WHEREFORE, the parties stipulate the deadline for filing the pretrial order be extended up to and including April 27, 2026 DATED this 23rd day of February 2026. DATED this 23rd day of February 2026. CLARK HILL PLLC DE CASTROVERDE LAW GROUP /s/ Nicholas M. Wieczorek /s/ Ryan Samano NICHOLAS M. WIECZOREK, ESQ. ALEX J. DE CASTROVERDE, ESQ. Nevada Bar No. 6170 Nevada Bar No. 6950 CAMI M. PERKINS, ESQ. RYAN SAMANO, ESQ. Nevada Bar No. 9149 Nevada Bar No. 15995 1700 South Pavilion Center Drive, Suite 500 1149 S. Maryland Pkwy. Las Vegas, Nevada 89135 Las Vegas, NV 89104 Attorneys for Defendant Attorneys for Plaintiffs LIBRA, LLC

IT IS SO ORDERED. _________________________________________ UNITED STATES MAGISTRATE JUDGE Date: February 25, 2026