Jose Luis Anaya Sanchez v. Southwest Citrus, LLC d/b/a Citrus Apartments; Does I through X; and Roe Business Entities I through X, inclusive

Opinion

1 Stacy R. Smith (NV Bar No.7919) stacy.smith@clydeco.com 7251 W. Lake Mead Blvd., Suite 430 3 Las Vegas NV 89128 Telephone: 725-248-2900 4 Attorney for Defendant 5 SOUTHWEST CITRUS, LLC D/B/A CITRUS APARTMENTS 6 9 JOSE LUIS ANAYA SANCHEZ, an CASE NO.: 2:25-cv-02357-CDS-DJA Individual, 10 11 Plaintiff, STIPULATION AND ORDER FOR LEAVE TO FILE FIRST AMENDED 12 v. COMPLAINT 13 SOUTHWEST CITRUS, LLC d/b/a CITRUS APARTMENTS, a Foreign 14 Limited Liability Company; DOES I through X; and ROE BUSINESS ENTITIES 15 I through X, inclusive, 16 Defendants. 17 18 IT IS HEREBY STIPULATED AND AGREED by Plaintiff JOSE LUIS ANAYA 19 SANCHEZ (“Plaintiff”) and Defendant SOUTHWEST CITRUS, LLC d/b/a CITRUS 20 APARTMENTS (“Defendant”), by and through their undersigned counsel, as follows: 22 1. On April 20, 2026, Plaintiff filed a Motion for Leave to File First Amended Complaint 23 seeking to name the following additional parties in place of previously identified ROE 24 Defendants: Banuelos Pro Landscaping, LLC, Omninet Property Management, LLC d/b/a 25 Pioneer Property Management; Omninet Southwest, LLC; and Omninet Capital, LLC. To 26 date, there has been no ruling on the Motion. 27 2. Defendant does not oppose Plaintiff amending the Complaint to add the following 28 additional parties in place of previously identified ROE Defendants: Banuelos Pro 1 Landscaping, LLC, Omninet Property Management, LLC d/b/a Pioneer Property 2 Management; Omninet Southwest, LLC. 3 3. Southwest Citrus, LLC, Omninet Property Management, LLC d/b/a Pioneer Property 4 Management; and Omninet Southwest, LLC have represented that they are covered entities 5 under the Sompo Commercial General Liability Insurance Policy that has been produced 6 herein and that they are entitled to coverage thereunder to the same extent as Omninet 7 Capital, LLC. 8 4. Southwest Citrus, LLC, Omninet Property Management, LLC d/b/a Pioneer Property 9 Management; and Omninet Southwest, LLC have further represented that they do not intend 10 to assert at trial that Omninet Capital, LLC owned or had any control over the sprinkler 11 system or walkways on the premises where the incident giving rise to this case occurred, 12 nor that Omninet Capital, LLC employed anyone with responsibility for exercising control 13 over said sprinkler system or walkway. 14 5. Based upon the foregoing representations, the parties have agreed that Plaintiff will not 15 amend the Complaint to add Omninet Capital, LLC as an additional party in place of 16 previously identified ROE Defendants. 17 6. On June 19, 2026, Defendant Southwest Citrus, LLC d/b/a Citrus Apartments filed a Motion 18 for Leave to File Third-Party Complaint against Banuelos Pro Landscaping, LLC for 19 contractual indemnification, equitable indemnity, and contribution. To date, there has been 20 no ruling on the Motion. 21 7. Plaintiff does not oppose Defendant’s Motion for Leave to File Third-Party Complaint 22 against Banuelos Pro Landscaping, LLC. 23 8. The parties agree that permitting Plaintiff to amend the Complaint to add the above- 24 referenced parties in place of previously identified ROE Defendants with expediency at this 25 stage of the litigation will minimize the potential need for a future discovery extension, 26 promote the efficient resolution of all claims arising out of the subject incident, and will 27 avoid the need for separate litigation. 28 9. This stipulation is made in good faith and not for purposes of delay. 2 IT IS HEREBY STIPULATED AND AGREED that: 3 1. Plaintiff shall have leave to file a First Amended Complaint naming Banuelos Pro 4 Landscaping, LLC, Omninet Property Management, LLC d/b/a Pioneer Property 5 Management; Omninet Southwest, LLC as additional parties in place of previously 6 identified ROE Defendants upon entry of this Order; 7 2. Plaintiff will not amend the Complaint to add Omninet Capital, LLC as an additional party 8 in place of previously identified ROE Defendants; 9 3. Plaintiff shall file the First Amended Complaint, in the form attached hereto as Exhibit A, 10 within seven (7) days of entry of an Order approving this Stipulation. 11 4. Defendants shall respond to the First Amended Complaint within the time permitted by the 12 Federal Rules of Civil Procedure. Further, Defendants anticipate filing a cross-claim against 13 newly named defendant Banuelos Pro Landscaping, LLC. 14 5. Upon entry of this Order, Plaintiff will withdraw his Motion for Leave to File First 15 Amended Complaint, and Defendant will withdraw its Motion for Leave to File Third-Party 16 Complaint, as both motions will be moot. 17 / / / 18 / / / 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 1 6. Southwest Citrus, LLC, Omninet Property Management, LLC d/b/a Pioneer Property 2 Management; and Omninet Southwest, LLC will not assert at trial that Omninet Capital, 3 LLC owned or had any control over the sprinkler system or walkways on the premises 4 where the incident giving rise to this case occurred, nor that Omninet Capital, LLC 5 employed anyone with responsibility for exercising control over said sprinkler system or 6 walkway. 7 8 Respectfully Submitted By: 9 Dated: July 10, 2026 Dated: July 10, 2026 10 CLYDE & CO US LLP GINA CORENA & ASSOCIATES 11 /s/ Stacy R. Smith /s/ Kristie L. Fischer 12 Stacy R. Smith, Esq. (NV Bar No. 7919) Kristie L. Fischer, Esq. (NV Bar No. 11693) 7251 W. Lake Mead Blvd., Suite 430 300 S. Fourth Street, Suite 1400 13 Las Vegas, NV 89128 Las Vegas, Nevada 89101 14 Attorney for Defendant, Attorney for Plaintiff, SOUTHWEST CITRUS, LLC JOSE LUIS ANAYA SANCHEZ 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Sanchez v. Southwest Citrus, LLC, 2 Case No.: 2:25-cv-02357-CDS-DJA 4 BASED ON THE STIPULATION OF THE PARTIES and good cause appearing; 5 therefore, 6 IT IS SO ORDERED that Plaintiff Jose Luis Anaya Sanchez shall have leave to file the 7 First Amended Complaint, attached hereto as Exhibit A, naming Banuelos Pro Landscaping, LLC, 8 Omninet Property Management, LLC d/b/a Pioneer Property Management, and Omninet 9 Southwest, LLC as additional Defendants in place of previously identified ROE defendants. 10 IT IS FURTHER ORDERED that Plaintiff Jose Luis Anaya Sanchez will not include 11 Omninet Capital, LLC as an additional Defendant in the First Amended Complaint. 12 IT IS FURTHER ORDERED that Southwest Citrus, LLC, Omninet Property 13 Management, LLC d/b/a Pioneer Property Management; and Omninet Southwest, LLC shall not 14 assert at trial that Omninet Capital, LLC owned or had any control over the sprinkler system or 15 walkways on the premises where the incident giving rise to this case occurred, nor that Omninet 16 Capital, LLC employed anyone with responsibility for exercising control over said sprinkler system 17 or walkway. 18 IT IS FURTHER ORDERED that Plaintiff shall file the First Amended Complaint, in the 19 form attached hereto as Exhibit A, within seven (7) days of entry of an Order approving this 20 Stipulation. 21 IT IS FURTHER ORDERED that Defendants shall respond to the First Amended 22 Complaint within the time permitted by the Federal Rules of Civil Procedure. 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 1 IT IS FURTHER ORDERED that Plaintiff Jose Luis Anaya Sanchez’s Motion for Leave 2 to File First Amended Complaint, and Defendant Southwest Citrus, LLC d/b/a Citrus Apartments’ 3 Motion for Leave to File Third-Party Complaint, are hereby viitharawn as moot. (ECF Nos. 12, 19 5 6 Dated:__ July 14,2026 0

8 □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ 9 UNITED STATES MAGISTRATE JUDGE 10 11 12 13 a 14 15 16

18 19 20 21 22 23 24 25 26 27 28

2 I am employed in the County of Los Angeles, State of California, I am over the age 3 of eighteen years, and not a party to the within action. My business address is 355 S. Grand 4 Avenue, Suite 1400, Los Angeles, CA 90071. 5 On July 10, 2026, I served the document(s) described as: STIPULATION AND 6 ORDER FOR LEAVE TO FILE FIRST AMENDED COMPLAINT on the parties in this action 7 addressed as follows: Kristie L. Fischer, Esq. 8 300 S. Fourth Street, Suite 1400 9 Las Vegas, Nevada 89101 Attorneys for Plaintiff, 10 JOSE LUIS ANAYA SANCHEZ 11 in the following manner: 12 BY FAX: by transmitting via facsimile the document(s) listed above to the fax number(s) set ☐ forth below on this date before 5:00 p.m. pursuant to EDCR Rule 7.26(a). A printed 13 transmission record is attached to the file copy of this document(s). 14 BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with postage ☐ thereon fully prepaid, in the United States mail at Las Vegas, Nevada addressed as set forth 15 below. 16 BY ELECTRONIC SERVICE: submitted to the above-entitled Court for electronic service  upon the Court’s Registered Service List for the above-referenced case. 17 BY EMAIL: by emailing a PDF of the document listed above to the email addresses of the ☐ 18 individual(s) listed below. 19 I declare under penalty of perjury according to the laws of the State of California 20 that the foregoing is true and correct. 21 Executed July 10, 2026, at Los Angeles, California. 22 /s/ Carolina Espinoza 23 Carolina Espinoza 24 25 26 27 28 EXHIBIT A

Plaintiff's First Amended Complaint 1 Gina M. Corena, Esq. Nevada Bar No. 10330 2 gina @ lawofficecorena.com Kristie L. Fischer, Esq. 3 Nevada Bar No. 11693 4 kristie @ lawofficecorena.com GINA CORENA & ASSOCIATES 5 300 S. Fourth Street, Suite 1400 Las Vegas, Nevada 89101 6 Telephone: (702) 680-1111 Facsimile: (888) 897-6507 7 Attorneys for Plaintiff ? DISTRICT OF NEVADA 10 JOSE LUIS ANAYA SANCHEZ, an | Case No. 2:25-cv-02357-CDS-DJA tl individual;

» Plaintiff, > PLAINTIFE’S FIRST oy, AMENDED COMPLAINT —_—_—_SSauroov 2‘'4 | sourHWEST CITRUS, LLC d/b/a ~ 45 CITRUS APARTMENTS, a Foreign Limited 0 Liability Company; BANUELOS PRO 16 LANDSCAPING, LLC, a Domestic Limited Liability Company; OMNINET 17 PROPERTY MANAGEMENT, _ INC. d/b/a PIONEER PROPERTY 18 MANAGEMENT, a Foreign Corporation; 19 OMNINET SOUTHWEST, LLC, a Foreign Limited Liability Company; 20 DOES I through X; and ROE BUSINESS ENTITIES I through X, inclusive, 21 Defendant. 22 23 24 Plaintiff JOSE LUIS ANAYA SANCHEZ (‘Plaintiff’), by and through attorneys o 25 record, the Law Office of GINA CORENA & ASSOCIATES, and for causes of action against th 26 Defendants, SOUTHWEST CITRUS, LLC d/b/a CITRUS APARTMENTS, a Foreign Limite 927 Liability Company; BANUELOS PRO LANDSCAPING, LLC, a Domestic Limited Liabilit 2g || Company; OMNINET PROPERTY MANAGEMENT, INC. d/b/a PIONEER □□□□□□□□ 1 of 10

1 MANAGEMENT, a Foreign Corporation; OMNINET SOUTHWEST, LLC, a Foreig: 2 Limited Liability Company; DOES I through X; and ROE BUSINESS ENTITIES I through X 3 } inclusive, and jointly and severally, complains and alleges as follows: 5 1. That at all times relevant hereto, Plaintiff, was and is a resident of Clark County 6 State of Nevada. 7 2. Upon information and belief, at all times mentioned, Defendant SOUTHWES’ 8 CITRUS, LLC d/b/a CITRUS APARTMENTS is a limited liability company formed under th 9 laws of the State of Delaware, with its principle place of business in Clark County, Nevada 10 ] and/or that owns and operates the residential apartment complex commonly known as CITRU: 2 Jil APARTMENTS, located at 60 N. Pecos Road, Las Vegas, Nevada 89101, and that was and i 5 12 || authorized to conduct, and was and is actually conducting business in Clark County, Nevada. 13 3. Upon information and belief, at all times mentioned, Defendant □□□□□□□□ 14 PRO LANDSCAPING, LLC is a limited liability company formed under the laws of th 15 State of Nevada, with its principle place of business in Clark County, Nevada, and/or tha 16 was and is contracted to perform landscape maintenance services at Citrus Apartment: 17 located at 60 N. Pecos Road, Las Vegas, Nevada 89101, and that was and is authorized t 18 conduct, and was and is actually conducting business in Clark County, Nevada. 19 4. Upon information and belief, at all times mentioned, Defendant OMNINE’ 20 | PROPERTY MANAGEMENT, INC. d/b/a PIONEER PROPERTY MANAGEMENT is | 21 foreign corporation formed under the laws of the State of California, that was and is th 22 property management company for Citrus Apartments, located at 60 N. Pecos Road, La 23 Vegas, Nevada 89101, and that was and is authorized to conduct, and was and is actuall: 24 conducting business in Clark County, Nevada. 25 5. Upon information and belief, at all times mentioned, Defendant OMNINE’ 26 SOUTHWEST, LLC is a foreign limited liability company formed under the laws of th 27 State of Delaware, that owns and/or operates the residential apartment complex □□□□□□□ 28 known as CITRUS APARTMENTS, located at 60 N. Pecos Road, Las Vegas, Nevada 89101 2 of 10

1 and that was and is authorized to conduct, and was and is actually conducting business it 2 Clark County, Nevada. 3 6. Pursuant to NRCP 10(a) and Nurenberger Hercules-Werke GMBH y. Virostek, 10 4 Nev. 873, 822 P.2d 1100 (1991), the identity of resident and non-resident Defendants designate 5 } herein as DOES I through X, and ROE BUSINESS ENTITIES I through X, are presentl: 6 unknown to Plaintiff. Upon information and belief these DOE and ROE Defendants, and each o 7 them, were involved in the initiation, approval, support, or execution of one or more of th 8 wrongful acts or omissions upon which this action is premised, or of similar actions directe: 9 against Plaintiff about which Plaintiff is presently unaware, and which directly and proximatel 10 caused injury and damages to Plaintiff, including but not limited to: unreasonably owning 2 maintaining, operating, or repairing the premises and/or any fixture or instrumentality thereon tha 5 12 || caused injury to Plaintiff G@ncluding but not limited to the sprinklers in the area where Plaintif 13 was injured). ROE and DOE Defendants also include but are not limited to: a) presentl unknown person(s) who is/are otherwise responsible for designing, constructing, improving 15 ) owning, leasing, controlling, operating, occupying, inspecting, managing, securing, cleaning 16 ] repairing, and/or maintaining the premises that includes the CITRUS APARTMENTS located a 17 60 N. Pecos Road, Las Vegas, NV 89101, Clark County, Nevada (hereinafter the “SUBJEC’ 18 PROPERTY’), at all times mentioned herein; b) persons involved in the design, manufacture 19 ) distribution, and placement into the stream of commerce of an unreasonably dangerous and unfi 20 product (including but not limited to the design, manufacture, sale, placement into the stream o 21 commerce, and installation of the sprinklers at the SUBJECT PROPERTY) that caused damage 22 to Plaintiff, and which persons are strictly liable under products liability law; c) employers o 23 Defendant(s) who are responsible for the acts of their employees under NRS 41.745, or under th 24 doctrine of respondeat superior; d) known witnesses whose particular culpability is not known 4 25 this time but may be made known once true facts are learned; and e) the predecessors an 26 successors of Defendants, and each of them, including but not limited to all parties that hav 27 assumed or retained the liabilities of any Defendant(s) by virtue of an agreement, sale, transfer o 28 otherwise. As the specific identities of these parties are revealed through discovery, the DOE o 3 of 10

1 ROE appellation will be replaced to identify these parties by their true names and capacities 2 Reference to Defendant or Defendants herein includes DOES and ROES and each of them. 3 7. At all times mentioned herein, Defendants, and each of them, were the agents 4 servants, partners, joint venturers, and/or employees of each and every other Defendant and wer 5 } acting within the course and scope of their agency, partnership, joint venture, and or/employment 7 8. Plaintiff repeats and realleges the allegations above as though fully set forth herein 8 9. On or about January 10, 2024, PLAINTIFF was an invitee of Defendants 9 walking through the SUBJECT PROPERTY. az 10 10. While at the SUBJECT PROPERTY, Plaintiff was walking to the Leasing Offic: 2 when he slipped on an icy sidewalk and fell, thereby sustaining serious injuries as a result (th », 5 || “SUBJECT INCIDENT’). VU 13 11. Prior to and at the time Plaintiff slipped and fell, Defendants, and each of ther . 14 || owned, utilized, and were charged with designing, constructing, improving, controlling 15 inspecting, cleaning, maintaining, and/or managing the premises that includes the □□□□□□ 16 APARTMENTS located at 60 N. Pecos Road, Las Vegas, NV 89101, Clark County, Nevada (i.e 17 the SUBJECT PROPERTY). 18 12. Upon information and belief, at all times relevant hereto, Defendant 19 SOUTHWEST CITRUS, LLC d/b/a CITRUS APARTMENTS, OMNINET □□□□□□□□ 20 MANAGEMENT, INC. d/b/a PIONEER PROPERTY MANAGEMENT, and OMNINE’ 21 SOUTHWEST, LLC, shared jointly in the benefits and burdens of owning, designing, building 22 marketing, and/or operation of the SUBJECT PROPERTY. 23 13. Upon information and belief, at all times relevant hereto, Defendan 24 BANUELOS PRO LANDSCAPING, LLC, was contracted to provide maintenance of th 25 landscaping of the SUBJECT PROPERTY. 26 14. At the time Plaintiff slipped and fell, Defendants, SOUTHWEST CITRUS, LL¢ 27 d/b/a CITRUS APARTMENTS, OMNINET PROPERTY MANAGEMENT, INC. d/b/ 28 PIONEER PROPERTY MANAGEMENT, and OMNINET SOUTHWEST, LLC, were th 4 of 10

1 owners and/or operators of the SUBJECT PROPERTY, and therefore had a non-delegable duty t 2 the general public and invitees, including Plaintiff, to maintain the SUBJECT PROPERTY in 3 } reasonably safe manner and to warn the general public and invitees on the SUBJEC 4 PROPERTY of safety hazards on the SUBJECT PROPERTY. 5 15. Prior to and at the time Plaintiff slipped and fell, Defendants were in control of th 6 } SUBJECT PROPERTY and had a duty to take reasonable steps to make the SUBJEC 7 PROPERTY safe for invitees and others present at the SUBJECT PROPERTY, which dut 8 includes but is not limited to the duty to supervise employees and staff, provide sufficier 9 security, identify and remediate potential slip, trip, and fall hazards, and clean maintain an 10 inspect the SUBJECT PROPERTY for the safety and protection of those persons present on th 2 ) SUBJECT PROPERTY including Plaintiff. 5 12 16. The presence of ice on the sidewalk constituted an unreasonably dangerou U 13 || condition and a trip hazard to guests, including Plaintiff. . 14 17. Defendants created the unreasonably dangerous condition by failing to maintai 15 the sprinklers at the property, directing the sprinklers in such a way as to cause overspray ont 16 pedestrian walkways, failing to direct (or re-direct) the sprinklers to avoid overspray ont 17 pedestrian walkways, allowing ice to accumulate on pedestrian walkways due to water spraye 18 onto the sidewalk by the sprinklers, failing to de-ice the walkways, and/or otherwise failing t 19 take reasonable steps to remediate the hazard created by the ice on the pedestrian walkways. 20 18. Before Plaintiff fell, Defendants knew or should have known that such a 21 unreasonable, unsafe, dangerous and/or hazardous condition existed and was □□□□□□□□□□□ 22 dangerous to guests. 23 19, Defendants did not take reasonable steps to safeguard guests who utilize this are 24 from the hazard presented by the icy sidewalk. 25 20. Defendants did not take reasonable steps to warn guests who utilize this area of th 26 hazard presented by the icy sidewalk. 27 21. Defendants did not secure the area, did not prevent guests from walking into an 28 through the area, did not remove the danger, did not provide warning to guests of the icy sidewall 5 of 10

1 or the danger associated therewith, and did not take any other reasonable steps to make th 2 SUBJECT PROPERTY safe for Plaintiff. 3 22. Defendants, and each of them, and/or their agents, employees and servants 4 breached the duty of care owed to Plaintiff by allowing the SUBJECT PROPERTY to b 5 maintained in such a negligent manner that it created an unreasonably dangerous condition. 6 23. Due to Defendants’ negligence, the area where Plaintiff fell was in a 7 unreasonable, unsafe, improperly maintained, dangerous and/or hazardous condition and wa 8 unreasonably dangerous to patrons and invitees, including Plaintiff. 9 24. Defendants’ employees’ negligence was committed within the scope of thei 10 employment with Defendants, and therefore these Defendants are vicariously liable to Plaintiff fo 2 the actions and/or failures to act of their employees, managers, agents, assigns, contractors 5 12 || subcontractors and/or others. 13 25. Defendants are solely at fault for the SUBJECT INCIDENT. . 14 26. As a direct and proximate result of the negligence, actions and/or omissions o 15 Defendants, and each of them, Plaintiff has suffered serious injuries to his body, all or some o 16 which conditions may be permanent or disabling in nature, as well as pain and suffering, anguish 17 disability, loss of earnings, loss of earning capacity, loss of enjoyment of life, and loss o 18 household services. 19 27. As a direct and proximate result of the negligence, actions and/or omissions o 20 Defendants, and each of them, Plaintiff has sustained damages in an amount in excess o 21 } $15,000.00. 22 28. As a direct and proximate result of the negligence, actions and/or omissions o 23 Defendants, and each of them, Plaintiff has had to retain the services of GINA CORENA & 24 ASSOCIATES to pursue this action and is entitled to recover costs of suit and reasonable attorney’ 25 fees incurred herein. 27 (Negligence as to All Defendants) 28 29. Plaintiff repeats and realleges the allegations above as though fully set forth herein 6 of 10

1 30. The SUBJECT INCIDENT described herein is of a kind which ordinarily does ne 2 occur in the absence of someone’s negligence. 3 31. The SUBJECT INCIDENT was caused by an agent or instrumentality within th 4 exclusive control of Defendant. 5 32. Plaintiff's negligence, if any, is not greater than that of Defendants. 6 33. Defendants had superior knowledge regarding the dangerous condition that cause 7 the SUBJECT INCIDENT than Plaintiff and therefore should have taken reasonable steps t 8 make the dangerous condition safe and/or to warn Plaintiff of the dangerous condition. 9 34. Defendants, and each of them, and their employees, contractors, and/o 10 subcontractors, created the hazard and had sufficient actual and/or constructive notice of th 2 Jil dangerous condition in sufficient time before the SUBJECT INCIDENT occurred, in order t 5 12 || have taken reasonable measures to protect against the SUBJECT INCIDENT and injuries 1 13 question. . 14 35. It was the duty of the Defendants, and each of them, to operate, design, construct 15 own, maintain, manage, clean, supervise, and/or operate the SUBJECT PROPERTY in 16 reasonably safe condition and/or manner, and further to warn of hazardous conditions, so as not t 17 negligently, carelessly, and recklessly cause injury or damage to others, including Plaintiff. 18 36. Defendants, and each of them, were negligent, or breached their duty of reasonabl 19 care, in the following particulars: 20 a. Defendants, individually or jointly, maintained, controlled, and/or created □ 21 dangerous condition on the SUBJECT PROPERTY by allowing ice to build □□□ 22 and remain on a sidewalk in an area designed for use by and actually used □□ 23 invitees; 24 b. The Defendants knew or should have known that the icy sidewalk in an are 25 designed for invitees to walk, was unsafe, nevertheless, Defendants, and eac! 26 of them, did not take steps to alleviate or prevent the dangerous condition, no 27 warn of its existence. 28 7 of 10

1 c. Defendants, and each of them, failed to implement reasonable policies an 2 procedures to operate, inspect, maintain, clean and/or repair the walkwa 3 where the SUBJECT INCIDENT occurred. 4 37. At all times mentioned herein, there were in effect statutes, ordinances, an 5 regulations prohibiting the conduct exhibited by Defendants. 6 38. Plaintiff was a member of the class of persons for whose protection said statutes 7 ordinances, and regulations were enacted and promulgated. 8 39, Plaintiff sustained injuries of the type that said statutes, ordinances, and regulation 9 were intended to prevent. az 10 40. As a direct and proximate result of the negligent actions and/or omissions o 2 Jil Defendants, and each of them, Plaintiff has sustained harms and losses, to be fully set forth an 5 12 || proven at trial, in an amount in excess of $15,000.00. 13 4l. As a direct and proximate result of the negligence, actions and/or omissions o 14 Defendants, and each of them, Plaintiff was required to obtain medical services and treatment an 15 may, in the future, be required to obtain additional medical services and treatment. 16 42. As a direct and proximate result of the negligence, actions and/or omissions o 17 Defendants, and each of them, Plaintiff has suffered physical injuries, as well as pain an 18 suffering, anguish, disability, loss of earnings, loss of earning capacity, loss of enjoyment of life 19 ] and loss of household services. 20 43. As a direct and proximate result of the negligence, actions and/or omissions o 21 Defendants, and each of them, Plaintiff has had to retain the services of Gina Corena é 22 Associates to pursue this action and is entitled to recover costs of suit and reasonable attorney’ 23 fees incurred herein. 25 (Negligent Hiring, Training, Supervision, and Retention as to All Defendants) 26 44. Plaintiff repeats and realleges the allegations above as though fully set forth herein 27 45. Defendants had a duty to use reasonable care in hiring, training, supervising, an 28 retaining employees and/or other persons and/or entities responsible for the design, construction 8 of 10

1 operation, maintenance, management, cleaning, and inspection of the SUBJECT PROPERTY t 2 ensure that a safe environment was provided for invitees, including Plaintiff. 3 A6. Defendants knew or should have known that the individuals hired and retained t 4 design, construct, operate, maintain, manage, clean, and/or inspect the SUBJECT □□□□□□□□ 5 were unfit to perform the duties assigned to them and/or unfit to follow policies and procedure 6 without training and supervision to reduce the risk of harm caused by Defendants and thei 7 employees acts or omissions. 8 47. Defendants breached their duty in that they failed to hire, train, and/or supervis 9 responsible employees, failed to train employees to keep the SUBJECT PROPERTY safe fo

1 Associates to pursue this action and is entitled to recover costs of suit and reasonable attorney’ 2 fees incurred herein. 4 WHEREFORE, Plaintiff expressly reserves the right to amend this Complaint at the tim: 5 of the trial of the action herein to include all parties and items of damage not yet ascertained 6 } demand judgment against Defendants and each of them, jointly and severally, as follows: 7 1. For general damages in an amount in excess of $15,000.00; 8 2. For special damages in an amount in excess of $15,000.00; 9 3, For interest at the legal rate; az 10 4, For cost of suit incurred herein;

w , tL 5. For reasonable attorney’s fees; and 5 - 12 6. For such other and further relief as the Court may deem just and proper. 4

HO

14 DATED: July 10, 2026. 15 GINA CORENA & ASSOCIATES 16 1 /s/ Kristie L. Fischer 7 Gina M. Corena, Esq. 18 Nevada Bar No. 10330 Kristie L. Fischer, Esq. 19 Nevada Bar No. 11693 300 S. Fourth Street, Suite 1400 20 Las Vegas, Nevada 89101 Attorneys for Plaintiff 21 22 23 24 25 26 27 28 10 of 10