Moten v. Goodwrx, LLC

Opinion

Jason Kuller, NV Bar No. 12244 1 || Rachel Mariner, NV Bar No. 16728 RAFI & ASSOCIATES, P.C. 2 || 1120 N. Town Center Dr., Suite 130 Las Vegas, Nevada 89144 3 || Telephone: 725.245.6056 Facsimile: 725.220.1802 4 || jason @rafiilaw.com rachel @ rafiilaw.com Attorneys for Plaintiffs 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA LAJUANA MOTEN and MARIO Case No. 2:25-cv-00778-APG-BNW 5 10 CARDENAS, on behalf of themselves and all others similarly situated, JOINT STIPULATION TO STAY oH Plaintifs DISCOVERY AND CASE DEADLINES v. , PENDING THE COURT’S RULING ON 5 PLAINTIFF’S MOTION FOR REMAND 13 || GOODWRX LLC, a Nevada Limited Liability | [ECF 11] AND DEFENDANT’S MOTION 0 Company; and DOES | through 50, inclusive, TO COMPEL ARBITRATION [ECF 10]

14 Defendants. (FIRST REQUEST) 15

16 17

19 IT IS HEREBY STIPULATED by and between Plaintiff LAJUANA MOTEN by and 20 through her counsel of record, Raffi & Associates, P.C., and Defendant GOODWRX LLC by and 21 through its counsel of record, Law Office of Mary Chapman, Ltd. (collectively “Parties”’), that all 22 discovery and case deadlines be stayed until the disposition of Plaintiff's pending Motion for 23 Remand (ECF 11) (“Remand Motion”) and Defendant’s pending Motion to Compel Arbitration 24 (ECF 10) (“Compel Motion”) (collectively “Motions”). This stipulation is submitted and based 25 upon the following: 26 1. This is the Parties’ first request for a stay of all discovery and case deadlines. 27 2. The Parties’ joint discovery plan and scheduling order (“DPSO”) is currently due to 28

1 || be filed on June 26, 2025. See ECF 9. 2 3. However, currently pending before the Court are Plaintiff's Remand Motion and 3 || Defendant’s Compel Motion. Resolution of either of these Motions could preclude further action 4 || in this Court by either of the Parties. 5 4. Hence, given the pendency of these Motions, the Parties desire to avoid the time and 6 || expense of negotiating and observing discovery deadlines, and to avoid wasting judicial resources 7 || on potentially unnecessary discovery disputes or motion practice. 8 5. Accordingly, the Parties have agreed to stay all discovery and case deadlines until 9 || the disposition of the Motions in order to conserve the Parties’ resources and for the sake of judicial - 10 || economy. 11 6. It is well recognized that “[c]ourts have broad discretion in managing their dockets.” 12 || Byars v. Western Best, LLC, No. 2:19-CV-1690-JCM-DJA, 2020 WL 8674195, at *1 (D. Nev. Jul. é 13 |} 6, 2020), citing Clinton v. Jones, 520 U.S. 681, 706-07 (1997). In exercising such discretion, “courts 14 || are guided by the goals of securing the just, speedy, and inexpensive resolution of actions.” Id.; see 5 15 || also Fed. R. Civ. P. 1. The Parties agree that good cause exists to stay discovery and all case 16 || deadlines while the Motions are pending, which might effectively require resolution of □□□□□□□□□□ 17 || claims in a state or arbitral forum. See Schrader v. Wynn Las Vegas, LLC, No. 2:19-cv-02159-JCM- 18 || BNW, 2021 WL 4810324, at *4 (D. Nev. Oct. 14, 2021); Aristocrat Techs., Inc. v. Light & Wonder, 19 || Inc., No. 2:24-CV-00382-GMN-MDC, 2024 WL 2302151, at *1 (D. Nev. May 21, 2024). 20 7. Proceeding with discovery before the Motions are resolved could cause unnecessary 21 || expense to the Parties and may clog the Court’s docket with potentially unnecessary discovery 22 || disputes or motion practice. Consistent with the foregoing, the Parties believe they will be in a 23 || better position to discuss or resume discovery, if at all, after the Motions are resolved. 24 8. For all these reasons, the Parties believe it is in the interest of judicial efficiency and 25 || economy to stay discovery and all case deadlines until the disposition of Plaintiff's Remand Motion 26 |} and Defendant’s Compel Motion. 27 9. In the event that both Motions are denied, the Parties will submit their joint DPSO 28 || within 14 days after the latter of the Court’s denials.

1 10. The Parties further agree that they are not waiving, relinquishing, or otherwise 2 || impairing any claim, defense, or other right they may have by virtue of entering into this Stipulation. 3 11. This request is made in good faith and not for the purpose of delay. 4 Dated: June 10, 2025 5 Law Office of Mary F. Chapman, Ltd. Rafii & Associates, P.C. /s/ Mary Chapman (with permission) /s/ Jason Kuller 7 Mary F. Chapman, Esq. Jason Kuller Nevada Bar No. 6591 Of Counsel 8 8440 W. Lake Mead Blvd, Suite 203 Nevada Bar No. 12244 Las Vegas, Nevada 89128 1120 N. Town Center Dr., Suite 130 9 Attorneys for Defendant Las Vegas, Nevada 89144 5 10 Attorneys for Plaintiffs

13 14 IT IS SO ORDERED:

15 Lg basin __ 16 UNITED STATES MAGISTRATE JUDGE

18 DATED: June 12, 2025 19 20 21 22 1. 23 24 25 26 27 28