Schrader v. Wynn

Opinion

1 || TRACY A. EGLET, ESQ. 3 Nevada Bar No. 6419 BRITTNEY R. GLOVER, ESQ. 3 || Nevada Bar No. 15412 EGLET ADAMS 4 || 400 South 7® Street, 4" Floor 5 || Las Vegas, Nevada 89101 Tel.: 702-450-5400 6 || Fax: 702-450-5451 eservice@egletlaw.com 7 and g || RICHARD A. HARRIS, ESQ. Nevada Bar No. 000505 9 || BURKE L. HUBER, ESQ. Nevada Bar No. 010902 yy |” | RICHARD HARRIS LAW FIRM 11 || 8015S. 4™ St. Las Vegas, Nevada 89101 12 || Tel.: 702-444-4444 Q 1B Fax: 702-444-4455 < burke@richardharrislaw.com 14 || Attorneys for Plaintiff a 15 UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA — 17 |) BRENNA SCHRADER, an individual, on behalf | Case No. 2:19-cv-02159-JCM-BNW co 18 of herself and all others similarly situated, 19 Plaintiff, DISCOVERY PLAN AND SCHEDULIN( ORDER PURSUANT TO THE COURT?’S 20 vs. ORDER REGARDING ECF #151 21 || STEPHEN ALAN WYNN; $an_ individual; MAURICE WOODEN, an individual, WYNN 22 || LAS VEGAS, LLC dba WYNN LAS VEGAS a 23 || Nevada Limited Liability, WYNN RESORTS, LTD, a Nevada Limited Liability Company; and 24 || DOES 1-20, inclusive; ROE CORPORATIONS 1-20, inclusive, 25 26 Defendants. 27 Plaintiff Brenna Schrader (“Plaintiff”), by and through her counsel of record, Eglet Adan 28 || and Richard Harris Law Firm, Defendants Wynn Las Vegas, LLC (““WLV”) and Wynn Resort Limited (““WRL”), by and through their counsel of record, Jackson Lewis P.C., and Defenda

1 || Stephen Alan Wynn (“Mr. Wynn”), by and through his counsel of record, Peterson Baker, PLL‘ 2 || hereby submits the following Discovery Plan and Scheduling Order Pursuant to the Court’s Ord 3 || Regarding ECF #151. I SUMMARY OF THE CASE This is a putative class action that arises from Plaintiff Brenna Schrader’s employment wi 4 Defendant WLV as a Massage Therapist. ECF No. 90, § 46. Defendant WRL is the indirect pare 2 company of WLYV. Plaintiff alleged various sexual misconduct that occurred during h 9 employment, from approximately 2012 to 2018. ECF No. 90. Plaintiff further alleges that she w: 10 subjected to co-worker harassment in 2019 and 2020. /d. at § 76. A. Procedural History. 11 12 On September 26, 2019, Plaintiff filed a putative Class Action Complaint in the Eigh Q 13 || Judicial District Court, Clark County, Nevada. The Summons and Complaint were served « 14 || Defendants WRL and WLV on November 25, 2019, and were attempted to be served upon M 15 || Wynn on December 11, 2019.1 ECF No. 1. The Complaint alleged six causes of action: ( 16 || discrimination and harassment in violation of 42 U.S.C. § 2000e et. seq. (Title VID and NR ml 17 11 608.017 (the Nevada Equal Pay Act); (2) violations of the Trafficking Victims Protection A 0 18 (TVPA) of 2000 (18 U.S.C. § 1589); (3) violations of the Federal Racketeer and Influence 19 Corrupt Organizations Act (RICO) (18 U.S.C. §§ 1962(b), (c), (d)); (4) Intentional Inflictions | 20 Emotional Distress (IED); (5) Conspiracy; and (6) violation of the Fair Labor Standards A 21 (FLSA) (29 U.S.C. § 206). Defendants removed this case to this Court on December 16, 2019. / 22 On March 6, 2020, Defendants filed numerous motions regarding Plaintiff’s Complai 23 and addressing potential discovery in this matter. WLV and WRL moved to dismiss Plaintiff 24 Complaint pursuant to FRCP 12(b)(6). ECF Nos. 35 (WLV’s Motion to Dismiss), 36 (WRL 25 26 'Mr. Wynn disputed service of process because the process server did not comply with Nevada law and did not lea 27 || acopy of the summons and complaint with a person who resided at Mr. Wynn's usual place of abode at the time. \ Wynn did not waive any issues regarding defective and/or insufficient service of process. ECF No. 11. □□□□□□□□ 28 || Wynn's counsel offered to accept service of the Summons and Complaint. Jd. Subsequently, the parties agreed tc date certain for Mr. Wynn's answer or other response to the Complaint. ECF No. 11.

1 || Motion to Dismiss), 37 (WRL’s Joinder to WLV’s MTD). WLV and WRL moved to stay discover 2 || pending resolution of their motions to dismiss. ECF No. 38. Mr. Wynn separately moved to dismi 3 || Plaintiff's Complaint and filed a joinder to WLV and WRL’s Motions to Dismiss. ECF No. 3 4 || Defendant Wooden filed a Motion for More Definite Statement, and alternatively joined in tl 5 Motions to Dismiss filed by WLV, WRL, and Mr. Wynn. ECF No. 33. On March 9, 202 6 Defendant Wooden joined WLV and WRL’s Motion to Stay Discovery. ECF No. 40. On Mar 10, 2020, Mr. Wynn also joined WLV and WRL's Motion to Stay Discovery. ECF No. 42. 8 Plaintiff filed her oppositions to Defendants’ Motions on May 8, 2020. ECF No. 54 (Op ° to WLV’s MTD) and 55 (Opp. to WRL’s MTD). On May 11, 2020, the Court granted WLV a1 " WRL’s Motion to Stay Discovery following Plaintiff’s non-opposition (ECF No. 56), directing tl 3 parties to file a joint proposed discovery plan and scheduling order within 14 days after the moti Q 3 to dismiss was decided. ECF No. 57. < 14 Defendants filed their respective Replies on June 19, 2020. ECF Nos. 63 (WLV’s Reply 15 ECF No. 64 (WRL’s Reply); ECF No. 66 (Defendant Wooden’s Reply); and ECF No. 67 (M 16 || Wynn’s Reply). BS 17 On July 27, 2020, in response to Defendants’ then-pending motions to dismiss, Plaint 18 || moved for leave to file a First Amended Complaint (“FAC”) consisting of 234 paragraphs spannit 19 || 42 pages, plus 253 pages of exhibits attached. ECF No. 69. The FAC included claims for: ( 20 || discrimination and harassment in violation of 42 U.S.C. § 2000e et. seq. (Title VII); (2) violatio: 21 || of the TVPA (18 U.S.C. § 1589); (3) violations of Federal RICO (18 U.S.C. §§ 1962(c); ¢ 22 || violations of Federal RICO (18 U.S.C. §§ 1962(b); (5) violations of Federal RICO (18 U.S.C. § 23 || 1962(d); (6) violation of Nevada RICO (NRS § 207.400); (7) ITED; (8) Conspiracy; and ( 24 |! violation of the Fair Labor Standards Act (FLSA) (29 U.S.C. § 206) and NRS 608, et seq.). Aft 25 full briefing on the matter, the Magistrate Judge issued a Report and Recommendation ¢ 26 December 9, 2020 granting Plaintiff’s motion except as to any claims under Nevada RIC 27 predicated on sex trafficking. ECF No. 81. °8 On December 23, 2020, Defendants filed objections to the Report and Recommendatio

1 || ECF Nos. 82 (Defendant Wooden’s Objection), 83 (Mr. Wynn’s Objection), and 84 (WLV ar 2 || WRL’s Objection). On February 17, 2021, the Court issued an order resolving the objections a1 3 || dismissing all of Plaintiffs claims except Title VII (against WLV and WRL), Nevada RIC 4 (against all defendants), ITED (against WLV, WRL, and Mr. Wynn), and Civil Conspiracy (again 5 |) Mr. Wynn). With respect to Plaintiff’s Nevada RICO claim, the Court denied Plaintiff’s motion 6 amend “‘to the extent she attempts to plead the predicate act of facilitating sex trafficking.” EC No. 89, 16:3-6. 8 On February 17, 2021, Plaintiff filed her First Amended Complaint, raising the causes | ° action set forth above on a class basis. Plaintiff defined a putative class consisting of ni " subclasses (discussed further below). On March 31, 2021, Defendant Wooden filed his Motion 3 Dismiss Plaintiff’s Nevada RICO claim (the sole remaining cause of action alleged again Q 13 Defendant Wooden). ECF No. 98. Also, on March 31, 2021, Mr. Wynn filed his Motion to Dism1 < 14 Plaintiffs claims for Nevada RICO, ITED, and civil conspiracy (the sole remaining causes | 15 action alleged against Mr. Wynn). ECF No. 99. On April 7, 2021, Mr. Wynn moved to contim 16 the stay of discovery based, in part, on the fact that it would be inefficient to proceed to discove: BS 17 |} on Plaintiff’s time-barred claims, which Defendant Wooden joined. ECF Nos. 101 and 102. C 18 || April 7, 2021, WLV and WRL filed their Motion to Dismiss Plaintiff’s Nevada RICO Claim 19 |} Plaintiff’s First Amended Complaint. ECF No. 103. Defendants WLV and WRL also filed Answe 20 || to Plaintiff’s First Amended Complaint. ECF Nos. 104 (WRL) and 105 (WRL). 21 B. Current Status of the Case 22 On March 31, 2022, the Court issued an order granting in part, and denying in pa 23 || Defendants’ respective Motions to Dismiss Plaintiff’s First Amended Complaint. ECF No. 14 24 Specifically, the Court dismissed Plaintiff’s claims under NRS 207.400 (Nevada RICO) as to ¢ 25 Defendants. /d., at 7:15-22. As to Mr. Wynn’s Motion to Dismiss Plaintiff’s ITED claim, the Cou 26 held that Plaintiff’s “time-barred allegations based on conduct from 2012 and 2015, and h 27 allegations against [Mr.] Wynn through a third-party VIP guest are dismissed with prejudic *8 Schrader’s ITED claim against [Mr.] Wynn based on her allegations of conduct that occurre

1 || between 2017 and 2018 remains.” /d., at 9:12-17. Plaintiff’s claims against Defendant Wood 2 || were dismissed in their entirety and as a result, Defendant Wooden is no longer a party in this cas 3 || Id., at 10:7-10. 4 Based on the foregoing, two claims remain against Defendants WLV and WRL—( iscrimination and Hostile Work Environment on the basis of sex m violation of [itle » at 5 |] Discriminati d Hostile Work Envi he basis of in violati f Title VII 6 (2) Intentional Infliction of Emotional Distress. /d., at 10:10-13. The claims remaining against M Wynn are (i) Civil Conspiracy, and (11) Intentional Infliction of Emotional Distress. /d., at 10:1. 18. 9 □□□ In addition, the following putative proposed Title VII class and subclasses remain at issu 10 a. All current and former female employees of WLV and WR, who were and 11 are subjected to severe and pervasive sexual discrimination while working for WLV and WR; Q b. All current and former female employees of WLV and WR, who were and < 13 are subjected to a sexually hostile work environment as a result of their 14 failure to prevent discrimination based upon sex (female); 15 c. All current and former female employees of WLV and WR, who were and are denied the same and similar conditions and terms of employment as male employees as a result of their sexual and gender discrimination. 16 | ploy: It of thei | and gender discriminati . current and former female employees o an , who were an BS "7 d. All d former female employees of WLV and WR, wh d are denied the same and similar conditions and terms of employment as 0 18 male employees as a result of their sexual and gender discrimination. 19 eee ECF No. 90, § 8. 20 C. This Court’s Order Regarding Bifurcated Discovery Pursuant to ECF No. 151 21 On May 20, 2022, the parties submitted their [Proposed] Joint Discovery Plan at

73 Scheduling Order. ECF No. 151. As the parties had different positions regarding wheth 4 bifurcation of discovery was necessary, the parties requested a scheduling conference with tl 5 Court in accordance with FRCP 16. /d. at 5:12-17. On May 25, 2022, the Court scheduled a hearir %6 regarding the parties’ [Proposed] Joint Discovery Plan and Scheduling Order for June 10, 2022 27 || 12:00 p.m. ECF No. 152. On June 6, 2022, based on the parties’ position regarding phase 28 || discovery, the Court ordered the parties to submit additional arguments no later than June 15, 202

1 || by 5:00 p.m. ECF No. 153. The Court further rescheduled the hearing regarding this matter to Jui 2 2022 at 1:00 p.m. Jd. On June 9, 2022, at the request of counsel for Mr. Wynn, the parti 3 || submitted a Stipulation to Continue Hearing Date and Extend Briefing Deadline Regardit 4 [Proposed] Joint Discovery Plan and Scheduling Order. ECF No. 154. On June 10, 2022, the Cou 5 granted the parties’ Stipulation. ECF No. 155. Accordingly, the deadline to submit supplement 6 briefing regarding the Discovery Plan and Scheduling Order was extended until June 29, 2022 a1 the hearing date was rescheduled to July 12, 2022 at 10:00 a.m. /d. On July 12, 2022, the Cou 8 heard oral argument from the respective parties regarding whether bifurcated discovery w: ° necessary and took the matter under submission. ECF No. 159. On July 14, 2022, the Court set " hearing for July 15, 2022 at 10:00 a.m. to issue an oral ruling regarding this matter. ECF No. 16 3 On July 15, 2022, the Court issued its oral ruling regarding the parties’ [Proposed] Joint □□□□□□□□ Q 3 Plan and Scheduling Order. < 14 The Court ruled that in exercising the Court’s broad discretion to control discovery, tl 15 Court is guided by FRCP Rule | to ensure a just, speedy, and inexpensive determination of eac 16 action. The Court found that a middle ground between the parties’ two positions best achieves tl BS 7 goals of Rule 1. co 18 The Court ordered that discovery should be bifurcated into two phases. The first pha 19 (“Phase 1”) will include discovery into the merits of Plaintiffs claims and discovery relevant 20 class certification. If a class is certified, the second phase (“Phase 2”) will include all remainir □□ discovery. As there will be some overlap between discovery that is relevant to class certificatic 4 and the merits of putative class members claims, during Phase 1, the parties will be allowed 73 obtain discovery related to the merits of putative class members, so long as it is also relevant 4 class certification. If discovery is only related to the merits of a putative class member’s clair 25 the Court will not allow it. 26 Should a dispute arise regarding whether discovery is permitted in Phase 1, the parties mu 7 meet and confer in good faith. The Court is available for informal discovery conferences on issu 2g that may arise. To request an informal conference, the party objecting to the discovery reque

1 || shall email Chambers a brief, not to exceed 5 pages, explaining the dispute and the party 2 || positions. The party requesting discovery shall have 3 days to file a response, not to exceed 3 || pages. The Court will then convene an informal discovery conference to conserve resources ar 4 || give the parties an understanding of how the Court may rule on the record in the event of ft 5 || briefing regarding the dispute. The parties may choose, not to engage in an informal discover 6 || process and may file their motions as deemed necessary. 7 On July 15, 2022, the Court issued its Minutes of Proceedings summarizing the oral □□□□ 8 || regarding the parties’ [Proposed] Joint Discovery Plan and Scheduling Order. ECF No. 161. TI 9 || transcript of the hearing on the parties’ [Proposed] Joint Discovery Plan and Scheduling Ord WY 10 || serves as the written order of the ruling. ECF No. 162. 3 Ml II. DISCOVERY PLAN V2 A. Fed R. Civ. P. 26(f) Scheduling Conference: The Parties held their initial schedulit conference pursuant to Fed. R. Civ. P. 26(f) on May 10, 2022 and a follow up conference on Mz 16, 2022. Based upon the Court’s oral ruling regarding the parties’ [Proposed] Joint Discove '° Plan and Scheduling Order, the parties submit the following Discovery Plan and Scheduling Ord ° Pursuant to the Court’s Order Regarding ECF #151: . B. Sched for Comp leting Phase 1 Discovery - Plaintiff-Merits and Class Certificatio1 elated Discovery:+ 19 1. Initial Disclosures: The initial disclosures to be made pursuant to Fed. | “0 Civ. P. 26(a)(1), which are relevant to Plaintiff-Merits and Cla 2 Certification-Related Discovery, shall be made by June 3, 2022. 2. Discovery Cut-Off Date: The last day of discovery for Phase 1 discove shall be November 14, 2022 which is 182 days after the date of the Parti 5 26(f) conference because the 180" day falls on Saturday, November 1 %6 2022, a non-judicial day. 27 || —— 28 |}? At the July 15, 2022 oral ruling hearing, this Court advised that the parties may seek to amend these deadlines | stipulation and/or motion as needed.

1 3. Amending the Pleadings and Adding Parties: The Parties shall have un 2 August 16, 2022, which is not later than ninety (90) days before the Pha 3 1 discovery deadline, to file any motions to amend the pleadings or to ac 4 parties. 5 4. Fed. R. Civ. P. 26(a)(2) Disclosures (Experts): Initial expert disclosur 6 are due September 15, 2022, which is not later than sixty (60) days befo the discovery cut-off date. Rebuttal expert disclosures are due on Octob 8 17, 2022, which is more than 30 days after the initial disclosure of exper ° because the thirtieth day falls on Saturday, October 15, 2022, a non-judici " day. 11 3 D 5. Dispositive Motions: Dispositive motions may be filed no later thi Q 13 December 14, 2022, which is thirty (30) days after the Phase 1 □□□□□□□□ < 14 deadline. To the extent the parties need additional time to respond or rep 15 to a dispositive motion, the parties must submit a stipulation or motion 16 the Court. BS 17 6. Rule 23 Class Certification Deadline: The last day for Plaintiff to file O 18 motion for class certification under FRCP 23 is February 17, 2023. To tl 19 extent the parties need additional time to respond or reply to the cla 20 certification motion, the parties must submit a stipulation or motion to tl 21 Court. 22 C. Schedule Completing Phase_2 Discovery — Class Member Merits-Relate 3 Discovery: 24 Phase 2 of discovery shall be stayed pending a ruling on Plaintiff's Motion for Cla 25 || Certification. If a class is certified, within fourteen (14) days of the Court’s decision certifying 26 || class, the parties shall file a Joint Proposed Discovery Plan and Scheduling Order as to ar 27 remaining discovery including deadlines for the same. If no class is certified, but any of tl 28 || Plaintiff's individual claims remain following the resolution of dispositive motions, the parti

1 || must file a Joint Proposed Pre-trial Order within thirty (30) days of (1) the Court’s ruling □□□□□□□ 2 || Plaintiff's individual claims to proceed; or (2) the Court’s decision not to certify class, whichev 3 || ruling is later. 4 D. Fed. R. Civ. P. 26(a)(3) Disclosures: The disclosures required by Fed. R. Civ. P. 26(a)(3 5 |) and any objections thereto, shall be included in the parties’ pretrial order. 6 E. Extensions or Modifications of the Discovery Plan and Scheduling Order: □ accordance with Local Rule 26-3, a stipulation or motion for modification or extension of th 8 discovery plan and scheduling order and any deadline contained herein, must be made not lat ° than twenty-one (21) days before the subject deadline. " F. Limitations on Discovery: The Parties agree that discovery should be limited by tl 3 statute of limitations/repose period applicable to the claims. Specifically, Plaintiff's Title VII clai Q 13 is limited to events occurring on or after August 30, 2018, which is 300 days prior to her intal < 14 with the U.S. Equal Employment Opportunity Commission (AMTRAK v. Morgan, 536 U.S. 10 15 105 (2002)); Plaintiff's IED claim is limited to events occurring on or after September 26, 201 16 which is two years prior to the filing of Plaintiff's Complaint on September 26, 2019 (NR BS 17 |} 11.190(4)(e)); and Plaintiffs claim for civil conspiracy is limited to events occurring on or aft 18 || September 26, 2015 which is four years prior to the filing of Plaintiff's Complaint (Siragusa 19 || Brown, 114 Nev. 1384, 1391-92, 971 P.2d 801, 806 (1998)). 20 G. Electronic Filing: The attorneys of record in this matter are registered for electronic filir 21 || with this Court and as such, consent to electronic service of any document required to be serve 22 || pursuant to Fed. R. Civ. P. 5. Any documents electronically filed with this Court are deemed to | 23 sufficiently served on the other party as of the date that the document ts electronically filed wi 24 |! the Court. 25 H. Electronically Stored Information: At this time, the parties do not anticipate any issu 26 regarding disclosures, discovery or preservation of electronically stored information (“ESI”), 27 any, including the form or forms in which it should be produced. The parties agree that ESI *8 be produced in paper form or as a readable image (e.g., .pdf or .tiff) file, while reserving the rig

1 || to thereafter seek production of the ESI in native format if necessary and to the extent readab 2 || images are insufficient in establishing any claims or defenses. If a party later requests the ESI1 3 || produced in its native format and/or as a forensic copy, the parties agree to meet and confer 4 || determine the parameters of the production and to produce according to the Federal Rules of Civ 5 || Procedure. The parties shall work in good faith with respect to the production of ESI, and me 6 and confer should any dispute arise. I. Electronic Evidence at Trial: In compliance with Local Rule 26-1(b)(9), the parti 8 certify they have discussed presenting evidence in an electronic format to jurors for the purpos: ° of jury deliberations. " J. Privileged or Protected Documents: The parties agree to be bound by Fed. R. Evid. 5( 3 regarding the disclosure of privileged material or work product. Further, the parties acknowled; Q 3 and agree that while each is taking reasonable steps to identify and prevent disclosure of ar < 14 document which they believe is privileged, there is a possibility that certain privileged materi 15 || may be produced inadvertently. Accordingly, the Parties agree that a party who produces 16 document protected from disclosure by the attomey-client privilege, attorney work produ BS 17 || doctrine or any other recognized privilege (“privileged document”) without intending to waive tl UO 18 || claim of privilege associated with such document may promptly notify the requesting party th 19 || such document was inadvertently produced and should have been withheld. Once the □□□□□□□□ 20 || party provides such notice to the requesting party, the requesting party must promptly return tl 21 || specified document(s) and any copies thereof. By complying with this obligation, the requestit 22 || party does not waive any right to challenge the assertion of privilege and request an order of tl 23 || Court denying such privilege. 24 K. Protective Orders for Confidential Documents and/or Information. The parties hav 25 discussed the need for a protective order for confidential documents and/or information ar 26 anticipate that a stipulated protective order will be necessary given the nature of Plaintiff 27 allegations. The parties will work together to agree on the terms of a stipulated protective orde 28 10

1 || In the event the parties cannot come to an agreement, they will engage in the meet and conf 2 || process before bringing the matter before the Court. 3 L. Alternative Dispute Resolution: In compliance with LR 26-1(b)(7), the parties □□□□□ 4 || that they met and conferred about the possibility of using alternative dispute resolution processe 5 |] but no agreement has been reached. The parties will continue to evaluate opportunities f 6 alternative dispute resolution. M. Alternative Forms of Case Disposition: In compliance with 28 U.S.C. § 636(c) and L 26-1(b)(8), the parties have considered consenting to trial by the assigned Magistrate Judge, | well as the Short Trial Program, but do not consent to trial by the magistrate judge or to the use. 10 the Court’s Short Trial Program. 1] 3 D DATED this 2nd day of September, 2022. Q 3 RICHARD HARRIS LAW FIRM JACKSON LEWIS P.C. 14 /s/ Burke Huber, Esq. /s/ Joshua A. Sliker, Esq. Richard Harris, Bar No. 505 Deverie J. Christensen, Bar No. 6596 15 Burke Huber, Bar No. 10902 Joshua A. Sliker, Bar No. 12493 16 801 S. Fourth Street 300 S. Fourth Street, Ste. 900 LL Las Vegas, Nevada 89101 Las Vegas, Nevada 89101 pel «217 Attorneys for Plaintiff Attorneys for Defendants 18 Brenna Schrader Wynn Las Vegas, LLC and Wynn Resorts, Ltd. 19 20 EGLET ADAMS PETERSON BAKER, PLLC 21 /s/Brittney Glover, Esq. /s/ Tamara Peterson, Esq. 9 Tracy A. Eglet, Bar No. 6419 Tamara Beatty Peterson, Bar No. 5218 Brittney Glover, Bar No. 15412 Nikki Baker, Bar No. 6562 23 400 S. 7th Street, Ste. 400 701 S. 7th Street Las Vegas, NV 89101 Las Vegas, Nevada 89101 24 5 Attorneys for Plaintiff Attorney for Defendant Brenna Schrader Stephen Alan Wynn 26 ORDER 27 IT IS SO ORDERED 28 DATED: 12:29 pm, September 13, 2022 Gua Les Are fat DWHNT'ATTL A CTY GNM

Bianca Marx

From: Tammy Peterson Sent: Thursday, August 25, 2022 11:22 AM To: Brittney Glover; Sliker, Joshua A. (Las Vegas); Christensen, Deverie J. (Las Vegas) Ce: Burke Huber; Danielle Miller; Bianca Marx; Nikki Baker; Williams, Hilary A. (Las Vegas); Chandler, Kelley (Las Vegas); Burke Huber Subject: RE: Schrader v. Wynn, et. al. - Computation of Damages

Brittney Yes, confirmed. But | did want to flag one issue: you have Burke listed at the Richard Harris law firm. Is that still his current firm? | thought he moved to the Van Law firm. The State bar lists his address as 1290 S. Jones. I’m copying his other email address on this email. Is Burke still representing plaintiff? Also, is the Richard Harris law firm still representing plaintiff? Regards

Beatty Peterson, Esq. Peterson Baker, PLLC 702.786.1001 From: Brittney Glover Sent: Tuesday, August 23, 2022 11:53 AM Tammy Peterson ; Sliker, Joshua A. (Las Vegas) ; Christensen, Deverie J. (Las Vegas) Cc: Burke Huber ; Danielle Miller ; Bianca Marx ; Nikki Baker ; Williams, Hilary A. (Las Vegas) ; Chandler, Kelley (Las Vegas) Subject: RE: Schrader v. Wynn, et. al. - Computation of Damages Perfect. Attached is the final version with Defendants’ edits incorporated. Please confirm that we have permission to affix your e-signature. Thanks.

Bianca Marx From: Sliker, Joshua A. (Las Vegas) Sent: Friday, September 2, 2022 1:27 PM To: Tammy Peterson; Brittney Glover; Christensen, Deverie J. (Las Vegas) Ce: Burke Huber; Danielle Miller; Bianca Marx; Nikki Baker; Williams, Hilary A. (Las Vegas); Chandler, Kelley (Las Vegas); Burke Huber Subject: RE: Schrader v. Wynn, et. al. - Computation of Damages

Brittney, have permission to affix my signature to the revised DPSO and the stipulation to extend. Thanks.

“ae «(Joshua A. Sliker (He/Him) Attorney at Law Jackson Lewis P.C. 300 S. Fourth Street Suite 900 Las Vegas, NV 89101 Direct: (702) 921-2486 | Main: (702) 921-2460 Joshua.Sliker@Jacksonlewis.com | www.jacksonlewis.com From: Tammy Peterson Sent: Tuesday, August 30, 2022 12:29 PM Brittney Glover ; Sliker, Joshua A. (Las Vegas) ; Christensen, Deverie J. (Las Vegas) Cc: Burke Huber ; Danielle Miller ; Bianca Marx ; Nikki Baker ; Williams, Hilary A. (Las Vegas) ; Chandler, Kelley (Las Vegas) ; Burke Huber Subject: RE: Schrader v. Wynn, et. al. - Computation of Damages

aD) aly Brittney Please see my comments and additional edits attached. If you make any further changes, could you please do that in an overlay to this Word version so that it’s easier to see your changes? Thanks. Regards

Beatty Peterson, Esq. Peterson Baker, PLLC 702.786.1001