Downes-Covington v. Las Vegas Metropolitan Police Department ( 2024 )

1 | |MARGARET A. MCLETCHIE, Nevada Bar No. 10931 LEO S. WOLPERT, Nevada Bar No. 12658 21 |MCLETCHIE LAW GROUP, PLLC 3 | {602 South 10™ Street Las Vegas, NV 89101 4 | | Telephone: (702) 728-5300 / Fax: (702) 425-8220 Email: efile@nvlitigation.com 5| | Counsel for Plaintiffs UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 81 | LANCE DOWNES-COVINGTON, an | Case. No.: 2:20-cv-01790-CDS-DJA g | |individual, SOLDADERA SANCHEZ, an individual, ROBERT O’BRIEN, an individual, 10||EMILY DRISCOLL, an individual, ALISON | STIPULATION AND ORDER TO KENADY, an individual, TENISHA MARTIN, | EXTEND DISCOVERY PLAN an individual, GABRIELA MOLINA, an | AND SCHEDULING ORDER 12 | | individual, DEADLINES Plaintiffs, 13 vs. (SIXTEENTH REQUEST) ll AS VEGAS METROPOLITAN POLICE 15||DEPARTMENT, in its official capacity; LIEUTENANT KURT MCKENZIE, as an 16 | |individual and in his capacity as a Las Vegas 3 17 Metropolitan Police Department Officer; OFFICER TABATHA DICKSON, as an 18 | |individual and in her capacity as a Las Vegas Metropolitan Police Department Officer; 19||CAPTAIN PATRICIA SPENCER, as an 20 individual and in her capacity as a Las Vegas Metropolitan Police Department Officer; 21 | |CAPTAIN DORI KOREN, as an individual and in his capacity as a Las Vegas Metropolitan Police 22 Department Officer; EVAN SPOON, as an 93 | | individual and in his capacity as a Las Vegas Metropolitan Police Department Officer; 24 | JORDAN TURNER, as an individual and in his capacity as a Las Vegas Metropolitan Police 25 | | Department Officer; UNKNOWN OFFICERS 1- 26 | | 14, as individuals and in their capacity as Las Vegas Metropolitan Police Department Officers, 27 28 Defendants. STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND “SCHEDULING ORDER DEADLINES (SIXTEENTH REQUEST) — 2 3 Plaintiffs Lance Downes-Covington, Soldadera Sanchez, Robert O’Brien, Emily 4 Driscoll, Alison Kenady, Tenisha Martin, and Gabriela Molina (“Plaintiffs”), by and through 5 their attorneys of record, Margaret A. McLetchie, Esq. and Leo S. Wolpert, Esq. with the ‘ law firm of McLetchie Law and Defendants, the Las Vegas Metropolitan Police Department 4 (the “Department” or “LVMPD”), Lieutenant Kurt McKenzie (“McKenzie”), Officer g Tabatha Dickson (“Dickson”), Captain Patricia Spencer (“Spencer”), Captain Dori Koren 9 (“Koren”), Officer Evan Spoon (“Spoon”), and Officer Jordan Turner (“Turner”), 10 collectively (““LVMPD Defendants”), by and through their attorneys of record, Craig R. Anderson, Esq. and Jackie V. Nichols, Esq., with the law firm of Marquis Aurbach, hereby stipulate and agree to extend the Discovery Plan and Scheduling Order deadlines an - 2B additional forty-five (45) days. This Stipulation is being entered in good faith and not for 14 purposes of delay (supplemented information noted in bold-face type). 15 1. STATUS OF DISCOVERY. 6 A, PLAINTIFFS’ DISCOVERY. 7 1. Plaintiffs’ Initial Disclosure of Witnesses and Documents Pursuant to FRCP 8 26.1(a)(1) dated January 20, 2021; 19 2. Plaintiff Lance Downes-Covington’s Responses to LVMPD’s First Set of Interrogatories dated May 13, 2021; > 3. Plaintiff Soldadera Sanchez’s Responses to LVMPD’s First Set of Interrogatories 9 dated May 13, 2021; 53 4. Plaintiff Robert O’Brien’s Responses to LVMPD’s First Set of Interrogatories dated May 13, 2021; 95 5. Plaintiff Emily Driscoll’s Responses to LVMPD’s First Set of Interrogatories dated May 13, 2021; 6. Plaintiff Alison Kenady’s Responses to LVMPD’s First Set of Interrogatories dated 3g May 13, 2021; STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 7. Plaintiff Tenisha Martin’s Responses to LVMPD’s First Set of Interrogatories dated 2 | |May 13, 2021; 3 8. Plaintiff Gabriela Molina’s Responses to LVMPD’s First Set of Interrogatories 4 | |dated May 13, 2021; 5 9. Plaintiff Lance Downes-Covington’s Responses to LVMPD’s First Set of Requests 6 | |for Production of Documents dated May 13, 2021; 7 10. Plaintiff Soldadera Sanchez’s Responses to LVMPD’s First Set of Requests for 8 | |Production of Documents dated May 13, 2021; 9 Plaintiff Robert O’Brien’s Responses to LVMPD’s First Set of Requests for 10 | |Production of Documents dated May 13, 2021; 11 Plaintiff Emily Driscoll’s Responses to LVMPD’s First Set of Requests for 12 | |Production of Documents dated May 13, 2021; 13 13. Plaintiff Alison Kenady’s Responses to LVMPD’s First Set of Requests for : 14 | |Production of Documents dated May 13, 2021; i ge: 15 14. Plaintiff Tenisha Martin’s Responses to LVMPD’s First Set of Requests for 16 | |Production of Documents dated May 13, 2021; 17 15. Plaintiff Gabriela Molina’s Responses to LVMPD’s First Set of Requests for 18 | |Production of Documents dated May 13, 2021; 19 16. Plaintiff Lance Downes-Covington’s First Set of Interrogatories to LVMPD dated 20 | |June 2, 2021; 21 17. Plaintiffs’ First Set of Requests for Production of Documents to LVMPD dated 22 | |June 2, 2021; 23 18. Plaintiff Emily Driscoll’s First Set of Interrogatories to LVMPD dated July 1, 2021; 24 19. Plaintiffs’ First Supplement to Initial Disclosure of Witnesses and Documents 25 | |Pursuant to FRCP 26.1(a)(1) dated July 1, 2021; 26 20. Plaintiffs’ Second Supplement to Initial Disclosure of Witnesses and Documents 27 | |Pursuant to FRCP 26.1(a)(1) dated July 8, 2021; 28 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST ] 21. Plaintiffs’ Third Supplement to Initial Disclosure of Witnesses and Documents 2 | |Pursuant to FRCP 26.1(a)(1) dated July 12, 2021; 3 Plaintiff Soldadera Sanchez’s Supplemental Responses to LVMPD’s First Set of 4 | |Interrogatories dated July 8, 2021; 5 23.Plaintiff Robert O’Brien’s Supplemental Responses to LVMPD’s First Set of 6 | |Interrogatories dated July 8, 2021; 7 24. Plaintiff Emily Driscoll’s Supplemental Responses to LVMPD’s First Set of 8 | |Interrogatories dated July 8, 2021; 9 25.Plaintiff Alison Kenady’s Supplemental Responses to LVMPD’s First Set of 10 | |Interrogatories dated July 8, 2021; 11 26. Plaintiff Tenisha Martin’s Supplemental Responses to LVMPD’s First Set of 12 | |Interrogatories dated June 8, 2021; 13 27. Plaintiff Soldadera Sanchez’s Supplemental Responses to LVMPD’s First Set of : 14 | |Requests for Production of Documents dated July 8, 2021; i ge: 15 28. Plaintiff Robert O’Brien’s Supplemental Responses to LVMPD’s First Set of 16 | |Requests for Production of Documents dated July 8, 2021; 17 29. Plaintiff Emily Driscoll’s Supplemental Responses to LVMPD’s First Set of 18 | |Requests for Production of Documents dated July 8, 2021; 19 30. Plaintiff Alison Kenady’s Supplemental Responses to LVMPD’s First Set of 20 | |Requests for Production of Documents dated July 8, 2021; 21 31.Plaintiff Tenisha Martin’s Supplemental Responses to LVMPD’s First Set of 22 | |Requests for Production of Documents dated July 8, 2021; 23 32. Plaintiff Gabriela Molina’s Supplemental Responses to LVMPD’s First Set of 24 | |Requests for Production of Documents dated July 8, 2021; 25 33. Plaintiff Gabriela Molina’s Second Supplemental Responses to LVMPD’s First Set 26 | |jof Requests for Production of Documents dated July 12, 2021; 27 34. Plaintiff Lance Downes-Covington’s Supplemental Responses to LVMPD’s First 28 | |Set of Requests for Production of Documents dated July 12, 2021; pF STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 35. Plaintiff Gabriela Molina’s Supplemental Responses to LVMPD’s First Set of 2 | |Interrogatories dated July 12, 2021; 3 36. Plaintiff Lance Downes-Covington’s Supplemental Responses to LVMPD’s First 4 | |Set of Interrogatories dated July 12, 2021; 5 37. Plaintiff Tenisha Martin’s First Set of Interrogatories to LVMPD dated July 13, 6 | |2021; 7 38. Plaintiffs’ Second Set of Requests for Production of Documents to LVMPD dated 8 | |July 13, 2021; 9 39. Plaintiff Tenisha Martin’s Second Set of Interrogatories to LVMPD dated July 14, 10 | |2021; 11 40. Plaintiffs’ Third Set of Requests for Production of Documents to LVMPD dated 12 | \July 14, 2021; 13 □□□ Plaintiffs’ Fourth Supplement to Initial Disclosure of Witnesses and Documents 14 | |Pursuant to FRCP 26.1(a)(1) dated September 15, 2021; i ge: 15 42. Plaintiff Tenisha Martin’s Third Set of Interrogatories to LVMPD dated September 16 | |15, 2021; 17 43. Plaintiffs’ Fourth Set of Requests for Production of Documents to LVMPD dated 18 | |September 15, 2021; 19 44. Plaintiffs’ First Set of Requests for Admission to LVMPD dated September 17, 20 | 2021; 21 45.Tenisha Martin’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 22 | |dated December 16, 2021; 23 46. Soldadera Sanchez’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 24 | |dated December 16, 2021; 25 47.Robert O’ Brien’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 26 | |dated December 16, 2021; 27 48.Lance Downes-Covington’s Responses to Lt. Kurt McKenzie’s First Set of 28 | |Interrogatories dated December 16, 2021; pS STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 49. Gabriela Molina’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 2 | |dated December 16, 2021; 3 50.Emily Driscoll’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 4 | |dated December 16, 2021; 5 51. Alison Kenady’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories 6 | |dated December 16, 2021; 7 52.Tenisha Martin’s Responses to LVMPD’s First Set of Requests for Admissions 8 | |dated December 16, 2021; 9 53. Soldadera Sanchez’s Responses to LVMPD’s First Set of Requests for Admissions 10 | |dated December 16, 2021; 11 54. Robert O’Brien’s Responses to LVMPD’s First Set of Requests for Admissions 12 | |dated December 16, 2021; 13 55.Lance Downes-Covington’s Responses to LVMPD’s First Set of Requests for : 14 | |Admissions dated December 16, 2021; 15 56. Gabriela Molina’s Responses to LVMPD’s First Set of Requests for Admissions 4 16 | |dated December 16, 2021; 17 57.Emily Driscoll’s Responses to LVMPD’s First Set of Requests for Admissions 18 | |dated December 16, 2021; 19 58. Alison Kenady’s Responses to LVMPD’s First Set of Requests for Admissions 20 | |dated December 16, 2021; 21 59. Alison Kenady’s First Set of Interrogatories to LVMPD dated April 1, 2022; 22 60. Emily Driscoll’s Second Set of Interrogatories to LVMPD dated April 1, 2022; 23 61. Gabriella Molina’s First Set of Interrogatories to LVMPD dated April 1, 2022; 24 62. Lance Downes-Covington’s Second Set of Interrogatories to LVMPD dated April 25 | |1, 2022; 26 63. Plaintiffs’ Fifth Set of Requests for Production of Documents to LVMPD dated 27 | |April 1, 2022; 28 64. Robert O’Brien’s First Set of Interrogatories to LVMPD dated April 1, 2022; □□ STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 65. Plaintiffs’ Second Set of Requests for Admissions to LVMPD dated April 1, 2022; 2 66. Sol Sanchez’s First Set of Interrogatories to LVMPD dated April 1, 2022; 3 Plaintiffs’ First Set of Requests for Production of Documents to Defendant Joe 4 | |Lombardo [Request Nos. 1-5] dated June 17, 2022; 5 68. Plaintiffs’ First Set of Requests for Admissions to Defendant Tabatha Dickson 6 | |dated June 17, 2022; 7 69. Plaintiffs’ First Set of Requests for Production of Documents to Defendant Joe 8 | |Lombardo [Request Nos. 1-4] dated June 17, 2022; 9 70. Soldadera Sanchez’s Second Set of Interrogatories to LVMPD dated June 17, 2022; 10 71.Robert O’Brien’s Second Set of Interrogatories to LVMPD dated June 17, 2022; 11 Emily Driscoll’s Third Set of Interrogatories to LVMPD dated June 17, 2022; 12 73. Lance Downes-Covington’s Third Set of Interrogatories to LVMPD dated June 17, 13 | |2022; 14 74. Plaintiffs’ Sixth Set of Requests for Production of Documents to LVMPD dated 15 | |June 17, 2022; 16 75. Plaintiffs’ Third Set of Requests for Admissions to LVMPD dated June 17, 2022; 17 76. Tenisha Martin’s Fourth Set of Interrogatories to LVMPD dated June 17, 2022; 18 77. Lance Downes-Covington’s First Set of Interrogatories to Officer Tabatha Dickson 19 | |dated June 17, 2022; 20 78.Soldadera Sanchez’s First Set of Interrogatories to Joe Lombardo dated June 17, 21 | |2022; 22 79. Soldadera Sanchez’s First Set of Interrogatories to Lt. Kurt McKenzie dated June 23 | 117, 2022; 24 80. Plaintiffs’ First Set of Requests for Production of Documents to Defendant Patricia 25 | |Spencer dated June 17, 2022; 26 81. Plaintiffs’ First Set of Requests for Production of Documents to Defendant Dori 27 | |Koren dated June 17, 2022; 28 pT STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 82. Plaintiffs’ First Set of Requests for Production of Documents to Joe Lombardo 2 | |[Request No. 1] dated June 17, 2022; 3 83. Plaintiffs’ First Set of Requests for Production of Documents to Lt. Kurt McKenzie 4 | |dated June 17, 2022; 5 84. Tenisha Martin’s First Set of Interrogatories to Lt. Kurk McKenzie dated June 17, 6 | |2022; 7 85. Plaintiffs’ Third Set of Requests for Admissions to LVMPD dated June 21, 2022; 8 86. Plaintiffs’ Sixth Set of Requests for Production of Documents to LVMPD dated 9 | |June 21, 2022; 10 87. Emily Driscoll’s Third Set of Interrogatories to LVMPD dated June 21, 2022; 11 88. Lance Downes-Covington’s Third Set of Interrogatories to LVMPD dated June 21, 12 | |2022; 13 89. Robert O’Brien’s Second Set of Interrogatories to LVMPD dated June 21, 2022; 14 90. Soldadera Sanchez’s First Set of Interrogatories to Lt. Kurt McKenzie dated June 15 | |21, 2022; 4 16 91.Soldadera Sanchez’s First Set of Interrogatories to Joe Lombardo dated June 21, 17 | 2022; 18 92. Soldadera Sanchez’s Second Set of Interrogatories to LVMPD dated June 21, 2022; 19 93. Plaintiffs’ First Set of Requests for Admissions to Officer Tabatha Dickson dated 20 | |June 21, 2022; 21 94. Plaintiffs’ First Set of Requests for Production of Documents to Joe Lombardo 22 | |[Request Nos. 1-5] dated June 21, 2022; 23 95. Plaintiffs’ First Set of Requests for Production of Documents to Lt. Kurt McKenzie 24 | |dated June 21, 2022; 25 96. Plaintiffs’ First Set of Requests for Production of Documents to Officer Tabatha 26 | |Dickson dated June 21, 2022; 27 97. Plaintiffs’ First Set of Requests for Production of Documents to Patricia Spencer 28 | |dated June 21, 2022; STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 98. Plaintiffs’ First Set of Requests for Production of Documents to Captain Dori Koren 2 | |dated June 21, 2022; 3 99. Lance Downes-Covington’s First Set of Interrogatories to Officer Tabatha Dickson 4 | |dated June 21, 2022; 5 100. Tenisha Martin’s First Set of Interrogatories to Lt. Kurt McKenzie dated 6 | |June 21, 2022; 7 101. Tenisha Martin’s Fourth Set of Interrogatories to LVMPD dated June 21, 8 | |2022; 9 102. Plaintiff Emily Driscoll’s Requests for Admissions to LVMPD - Set One 10 | |dated October 27, 2022. 11 103. Plaintiff Emily Driscoll's Interrogatories to LVMPD - Set Four dated 12 | |October 27, 2022. 13 104. Plaintiff Emily Driscoll's Interrogatories to Tabatha Dickson - Set One 14 | |dated October 27, 2022. i ge: 15 105. Plaintiff Emily Driscoll's Requests for Production of Documents to 16 | |LVMPD - Set One dated October 27, 2022. 17 106. Plaintiff Emily Driscoll's Requests for Production of Documents to Tabatha 18 | |Dickson - Set One dated October 27, 2022. 19 107. Plaintiff Emily Driscoll's Requests for Admissions to Tabatha Dickson - Set 20 | |One dated October 27, 2022. 21 108. Plaintiff Gabriela Molina's Interrogatories to LVMPD - Set Two dated 22 | |October 27, 2022. 23 109. Plaintiff Gabriela Molina's Interrogatories to Tabatha Dickson - Set One 24 | |dated October 27, 2022. 25 110. Plaintiff Gabriela Molina’s Requests for Production of Documents to 26 | |LVMPD - Set One dated October 27, 2022. 27 111. Plaintiff Gabriela Molina’s Requests for Production of Documents to 28 | |Tabatha Dickson - Set One dated October 27, 2022. STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST ] 112. Plaintiff Gabriela Molina's Requests for Admissions to LVMPD - Set One 2 | |\dated October 27, 2022. 3 113. Plaintiff Gabriela Molina’s Requests for Admissions to Tabatha Dickson - |Set One dated October 27, 2022. 5 114. Plaintiff Lance Downes-Covington's Interrogatories to LVMPD - Set Four 6 | |dated October 27, 2022. 7 115. Plaintiff Lance Downes-Covington's Interrogatories to Tabatha Dickson - 8 | |Set Two dated October 27, 2022. 9 116. Plaintiff Lance Downes-Covington's Interrogatories to Jordan Turner - Set 10 | |One dated October 27, 2022. 11 117. Plaintiff Lance Downes-Covington's Requests for Production of Documents 12 | |to LVMPD - Set One dated October 27, 2022. 13 118. Plaintiff Lance Downes-Covington's Requests for Production of Documents : 14 | |to Tabatha Dickson - Set One dated October 27, 2022. i : 15 119. Plaintiff Lance Downes-Covington's Requests for Production of Documents 16 | |to Jordan Turner - Set One dated October 27, 2022. 17 120. Plaintiff Lance Downes-Covington's Requests for Admissions to LVMPD 18 | |- Set One dated October 27, 2022. 19 121. Plaintiff Lance Downes-Covington's Requests for Admissions to Tabatha 20 | |Dickson - Set One dated October 27, 2022. 21 122. Plaintiff Lance Downes-Covington's Requests for Admissions to Jordan 22 | |Turner - Set One dated October 27, 2022. 23 123. Soldadera Sanchez's Requests for Production of Documents to LVMPD - 24 | |Set One dated November 7, 2022. 25 124. Soldadera Sanchez's Requests for Admissions to LVMPD - Set One dated 26 | |November 7, 2022. 27 125. Robert O'Brien's Interrogatories to LVMPD - Set One dated November 7, 28 | |2022. 10 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 126. Robert O'Brien's Requests for Production of Documents to LVMPD - Set 2 | |One dated November 7, 2022. 3 127. Robert O'Brien's Requests for Admissions to LVMPD - Set One dated 4 | |November 7, 2022. 5 128. Alison Kenady's Interrogatories to LVMPD - Set Two dated November 7, 6 | |2022. 7 129. Alison Kenady's Requests for Production of Documents to LVMPD - Set 8 | |One dated November 7, 2022. 9 130. Alison Kenady's Requests for Admissions to LVMPD - Set One dated 10 | |November 7, 2022. 11 131. Tenisha Martin's Requests for Production of Documents to LVMPD - Set 12 | |One dated November 7, 2022. 13 132. Tenisha Martin's Requests for Admissions to LVMPD - Set One dated 14 | [November 7, 2022. i ge: 15 133. Plaintiffs’ Fifth Supplement to Initial Disclosure of Witnesses and 16 | |Documents Pursuant to FRCP 26.1(a)(1) dated January 4, 2023; 17 134. Plaintiffs’ Sixth Supplement to Initial Disclosure of Witnesses and 18 | |Documents Pursuant to FRCP 26.1(a)(1) dated January 20, 2023. 19 135. Tenisha Martin’s Requests for Production of Documents to LVMPD - Set 20 | |Two, dated January 17, 2023. 21 136. Tenisha Martin’s Requests for Production of Documents to LVMPD □ Set 22 | |Three, dated April 18, 2023. 23 137. Plaintiff Lance Downes-Covington’s Requests for Production to LVMPD - 24 | |Set Two dated May 16, 2023. 25 138. Plaintiff Gabriela Molina’s Requests for Admissions to LVMPD - Set Two 26 | |dated June 14, 2023. 27 139. Plaintiffs’ Eighth Supplemental Disclosure of Witnesses and Documents 28 | |Pursuant to FRCP 26.1(a)(1) dated January 30, 2024. 1] STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 140. Plaintiffs’ Ninth Supplemental Disclosure of Witnesses and Documents 2 | |Pursuant to FRCP 26.1(a)(1) dated February 27, 2024. 3 141. Plaintiffs’ Tenth Supplemental Disclosure of Witnesses and Documents 4 | Pursuant to FRCP 26. 1(a)(1) dated April 18, 2024. ° B. DEFENDANTS’ DISCOVERY. 6 1. LVMPD Defendants’ Initial Disclosure of Witnesses and Documents Pursuant to FRCP 26.1(a)(1) dated January 20, 2021. 8 2. LVMPD’s First Set of Interrogatories to Plaintiff Lance Downes-Covington dated March 12, 2021. 10 3. LVMPD’s First Set of Interrogatories to Plaintiff Soldadera Sanchez dated March 12, 2021. 12 4. LVMPD’s First Set of Interrogatories to Plaintiff Robert O’Brien dated March 12, _ Jooa1. 5. LVMPD’s First Set of Interrogatories to Plaintiff Emily Driscoll dated March 12, 2021. 16 6. LVMPD’s First Set of Interrogatories to Plaintiff Alison Kenady dated March 12, 1 2021. 18 7. LVMPD’s First Set of Interrogatories to Plaintiff Tenisha Martin dated March 12, 19 2021. 20 8. LVMPD’s First Set of Interrogatories to Plaintiff Gabriela Molina dated March 12, 21 2021. 22 9. LVMPD’s First Set of Request for Production of Documents to Plaintiff Lance 23 Downes-Covington dated March 12, 2021. 24 10. LVMPD’s First Set of Request for Production of Documents to Plaintiff Soldadera 2 Sanchez dated March 12, 2021. 26 11. LVMPD’s First Set of Request for Production of Documents to Plaintiff Robert 27 O’Brien dated March 12, 2021. 28 12 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST ] 12. LVMPD’s First Set of Request for Production of Documents to Plaintiff Emily 2 | |Driscoll dated March 12, 2021. 3 13. LVMPD’s First Set of Request for Production of Documents to Plaintiff Alison 4 | |Kenady dated March 12, 2021. 5 14. LVMPD’s First Set of Request for Production of Documents to Plaintiff Tenisha 6 | |Martin dated March 12, 2021. 7 15. LVMPD’s First Set of Request for Production of Documents to Plaintiff Gabriela 8 | |Molina dated March 12, 2021. 9 16.LVMPD Defendants’ First Supplement to Initial Disclosures of Witnesses and 10 | |Documents Pursuant to FRCP 26.1(a)(1) dated July 20, 2021. 11 17.LVMPD’s Answers to Plaintiff Lance Downes-Covington’s First Set of 12 | |Interrogatories dated July 20, 2021. 13 18.LVMPD’s Responses to Plaintiffs’ First Set of Requests for Production of : 14 | |Documents dated July 20, 2021. i : 15 19. LVMPD’s Responses to Plaintiff Emily Driscoll’s First Set of Interrogatories dated 16 | |August 3, 2021. 17 20. LVMPD’s Supplemental Answers to Plaintiff Lance Downes-Covington’s First Set 18 | Interrogatories dated August 3, 2021. 19 21.LVMPD’s Supplemental Responses to Plaintiffs’ First Set of Requests for 20 | |Production of Documents dated August 3, 2021. 21 22. LVMPD Defendants’ Second Supplement to Initial Disclosures of Witnesses and 22 | |Documents Pursuant to FRCP 26.1(a)(1) dated August 4, 2021. 23 23. LVMPD’s Supplemental Answers to Plaintiff Lance Downes-Covington’s First Set 24 | |of Interrogatories dated August 9, 2021. 25 24.LVMPD Defendants’ Third Supplement to Initial Disclosures of Witnesses and 26 | |Documents Pursuant to FRCP 26.1(a)(1) dated August 16, 2021. 27 25. LVMPD’s Responses to Plaintiff Tenisha Martin’s First Set of Interrogatories dated 28 | |August 16, 2021. 13 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 26. LVMPD’s Responses to Plaintiff Tenisha Martin’s Second Set of Interrogatories 2 | |dated August 16, 2021. 3 27.LVMPD’s Responses to Plaintiffs’ Third Set of Requests for Production □□ 4 | |Documents dated August 16, 2021. 5 28.LVMPD’s Responses to Plaintiffs’ Second Set of Requests for Production □□ 6 | |Documents dated August 30, 2021. 7 29. LVMPD’s Responses to Plaintiff Tenisha Martin’s Second Set of Interrogatories 8 | |dated August 30, 2021. 9 30. LVMPD Defendants’ Fourth Supplement to Initial Disclosures of Witnesses and 10 | |Documents Pursuant to FRCP 26.1(a)(1) dated August 30, 2021. 11 31. LVMPD Defendants’ Privilege Log dated August 30, 2021. 12 32. LVMPD’s Amended Responses to Plaintiffs’ Third Set of Requests for Production 13 | }of Documents dated September 13, 2021. 14 33. LVMPD’s Amended Responses to Plaintiffs’ Second Set of Requests for i ge: 15 | |Production of Documents dated September 13, 2021. 4 16 34. LVMPD’s Amended Responses to Plaintiff Tenisha Martin’s Second Set of 17 | |Interrogatories dated September 13, 2021. 18 35.LVMPD’s Amended Responses to Plaintiff Emily Driscoll’s First Set of 19 | |Interrogatories dated September 13, 2021. 20 36. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Lance Downes-Covington 21 | |dated September 22, 2021. 22 37.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Soldadera Sanchez dated 23 | |September 22, 2021. 24 38.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Robert O’Brien dated 25 | |September 22, 2021. 26 39.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Emily Driscoll dated 27 | |September 22, 2021. 28 □ STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 40.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Alison Kenady dated 2 | |September 22, 2021. 3 41.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Tenisha Martin dated 4 | |September 22, 2021. 5 42.Lt. McKenzie’s First Set of Interrogatories to Plaintiff Gabriela Molina dated 6 | |September 22, 2021. 7 43.LVMPD’s First Set of Requests for Admission to Plaintiff Lance Downes- 8 | |Covington dated September 22, 2021. 9 44.LVMPD’s First Set of Requests for Admission to Plaintiff Soldadera Sanchez dated 10 | |September 22, 2021. 11 45.LVMPD’s First Set of Requests for Admission to Plaintiff Robert O’Brien dated 12 | |September 22, 2021. 13 46. LVMPD’s First Set of Requests for Admission to Plaintiff Emily Driscoll dated 14 | |September 22, 2021. 15 47.LVMPD’s First Set of Requests for Admission to Plaintiff Alison Kenady dated 16 | |September 22, 2021. 17 48.LVMPD’s First Set of Requests for Admission to Plaintiff Tenisha Martin dated 18 | |September 22, 2021. 19 49.LVMPD’s First Set of Requests for Admission to Plaintiff Gabriela Molina dated 20 | |September 22, 2021. 21 50. LVMPD Defendants’ Fifth Supplement to Initial Disclosures of Witnesses and 22 | |Documents Pursuant to FRCP 26.1(a)(1) dated October 11, 2021. 23 51. LVMPD’s Responses to Plaintiffs’ Fourth Set of Requests for Production of 24 | |Documents dated October 18, 2021. 25 52. LVMPD’s Responses to Plaintiff Tenisha Martin’s Third Set of Interrogatories 26 | |dated October 18, 2021. 27 53. LVMPD’s Responses to Plaintiffs’ First Set of Requests Admission dated October 28 | |20, 2021. 15 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 54. LVMPD’s Answers to Plaintiff Lance Downes-Covington’s Second Set of 2 | |Interrogatories dated May 5, 2022. 3 55. LVMPD’s Answers to Plaintiff Alison Kenady’s First Set of Interrogatories dated 4 | |May 5, 2022. 5 56. LVMPD’s Answers to Plaintiff Robert O’Brien’s First Set of Interrogatories dated 6 | |May 5, 2022. 7 57.LVMPD’s Answers to Plaintiff Sol Sanchez’s First Set of Interrogatories dated 8 | |May 5, 2022. 9 58.LVMPD’s Responses to Plaintiffs’ Fifth Set of Requests for Production of 10 | |Documents dated May 5, 2022. 11 59. LVMPD’s Answers to Plaintiff Emily Driscoll’s Second Set of Interrogatories 12 | |dated May 5, 2022. 13 60. LVMPD’s Answers to Plaintiff Gabriella Molina’s First Set of Interrogatories dated 14| |May 5, 2022. 15 61. LVMPD’s Responses to Plaintiffs’ Second Set of Requests for Admissions dated 16 | |May 5, 2022. 17 62. LVMPD’s Second Supplemental Answers to Plaintiff Lance Downes-Covington’s 18 | |First Set of Interrogatories dated June 24, 2022. 19 63. LVMPD’s First Supplemental Responses to Plaintiffs’ Second Set of Requests for 20 | |Production of Documents dated June 24, 2022. 21 64. LVMPD’s First Supplemental Answers to Plaintiff Tenisha Martin’s Second Set of 22 | |Interrogatories dated June 24, 2022. 23 65. LVMPD’s Second Supplemental Responses to Plaintiffs’ First Set of Requests for 24 | |Production of Documents dated June 24, 2022. 25 66. Lt. Kurt McKenzie's Answers to Soldadera Sanchez's First Set of Interrogatories 26 | |dated August 8, 2022. 27 67. Lt. Kurt McKenzie's Answers to Tenisha Martin's First Set of Interrogatories dated 28 | |August 8, 2022. 16 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 68. Lt. Kurt McKenzie's Responses to Plaintiffs' First Set of Requests for Production 2 | |jof Documents dated August 8, 2022. 3 69. Patricia Spencer's Responses to Plaintiffs’ First Set of Requests for Production of 4 | |Documents dated August 8, 2022. 5 70. Tabatha Dickson's Responses to Plaintiffs’ First Set of Requests for Admissions 6 | |dated August 8, 2022. 7 71.Tabatha Dickson's Answers to Lance Downes-Covington's First Set of 8 | |Interrogatories dated August 8, 2022. 9 72.LVMPD's Responses to Plaintiffs' Third Set of Requests for Admissions dated 10 | |August 8, 2022. 11 73.LVMPD's Answers to Lance Downes-Covington's Third Set of Interrogatories 12 | |dated August 8, 2022. 13 74.LVMPD's Answers to Soldadera Sanchez's Second Set of Interrogatories dated 14 | [August 8, 2022. 15 75.Captain Dori Koren's Responses to Plaintiffs’ First Set of Requests for Production 4 16 | jof Documents dated August 8, 2022. 17 76. Tabatha Dickson's Responses to Plaintiffs’ First Set of Requests for Production of 18 | |Documents dated August 8, 2022. 19 77.LVMPD's Answers to Robert O'Brien's Second Set of Interrogatories dated August 20 | |8, 2022. 21 78. LVMPD's Answers to Tenisha Martin's Fourth Set of Interrogatories dated August 22 | |8, 2022. 23 79.LVMPD's Responses to Plaintiffs’ Sixth Set of Requests for Production of 24 | |Documents dated August 8, 2022. 25 80. LVMPD's Answers to Emily Driscoll's Third Set of Interrogatories dated August 26 | |8, 2022. 27 81. LVMPD Defendants’ Sixth Supplemental FRCP 26.1 Disclosures dated August 8, 28 | |2022. 17 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 82. LVMPD Defendants' Seventh Supplemental FRCP 26.1 Disclosures dated 2 | |December 6, 2022. 3 83. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for Production 4 | |— Set One, dated December 6, 2022. 5 84. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for Admission 6 | |— Set One, dated December 6, 2022. 7 85.Jordan Turner’s Responses to Lance Downes-Covington’s Interrogatories — Set 8 | |One, dated December 6, 2022. 9 86. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for Admission 10 | |— Set One, dated December 6, 2022. 11 87.Jordan Turner’s Responses to Gabriela Molina’s Requests for Production — Set 12 | |One, dated December 6, 2022. 13 88.Tabatha Dickson’s Reponses to Lance Downes Covington’s Requests for : 14 | |Production — Set One, dated December 6, 2022. i ge: 15 89. Tabatha Dickson’s Responses to Lance Downes-Covington’s Interrogatories — Set 16 | |One, dated December 6, 2022. 17 90. Tabatha Dickson’s Responses to Lance Downes-Covington’s Interrogatories — Set 18 | |Two, dated December 6, 2022. 19 91.Tabatha Dickson’s Responses to Lance Downes-Covington’s Requests for 20 | |Admission — Set One, dated December 6, 2022. 21 92.Tabatha Dickson’s Responses to Lance Downes-Covington’s Requests for 22 | |Production — Set One, dated December 6, 2022. 23 93. Tabatha Dickson’s Responses to Gabriela Molina’s Interrogatories — Set One, dated 24 | |December 6, 2022. 25 94. Tabatha Dickson’s Responses to Gabriela Molina’s Requests for Admission — Set 26 | |One, dated December 6, 2022. 27 95. Tabatha Dickson’s Responses to Gabriela Molina’s Interrogatories — Set One, dated 28 | |December 6, 2022. 18 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 96. Tabatha Dickson’s Responses to Gabriela Molina’s Requests for Production — Set 2 | |One, dated December 6, 2022. 3 97. Tabatha Dickson’s Responses to Emily Driscolls’ Requests for Admission — Set 4 | |One, dated December 6, 2022. 5 98. Tabatha Dickson’s Responses to Emily Driscolls’ Interrogatories — Set One, dated 6 | |December 6, 2022. 7 99. LVMPD’S Responses to Lance Downes Covington’s Requests for Production — Set 8 | |One, dated December 6, 2022. 9 100. LVMPD’S Responses to Lance Downes Covington’s Requests for 10 | |Admission — Set One, dated December 6, 2022. 11 101. LVMPD’S Responses to Lance Downes Covington’s Interrogatories — Set 12 | |Four, dated December 6, 2022. 13 102. LVMPD’s Responses to Emily Driscolls’ Interrogatories — Set One, dated 14 | |December 6, 2022. 15 103. LVMPD’s Responses to Emily Driscolls’ Interrogatories — Set Four, dated 16 | |December 6, 2022. 17 104. LVMPD’s Responses to Emily Driscolls’ Requests for Admission — Set 18 | |One, dated December 6, 2022. 19 105. LVMPD’s Responses to Emily Driscolls’ Requests for Production — Set 20 | |One, dated December 6, 2022. 21 106. LVMPD’s Responses to Gabriela Molina’s Interrogatories — Set Two, dated 22 | |December 6, 2022. 23 107. LVMPD’s Responses to Gabriela Molina’s Requests for Production— Set 24 | |One, dated December 6, 2022. 25 108. LVMPD’s Responses to Gabriela Molina’s Requests for Admission — Set 26 | |One, dated December 6, 2022. 27 109. LVMPD Defendants’ Eighth Supplemental FRCP 26.1 Disclosures dated 28 | |December 16, 2022. 19 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 110. LVMPD’S Responses to Tenisha Martin’s Requests for Admission — Set 2 | |One, dated December 19, 2022. 3 111. LVMPD’S Responses to Soldadera Sanchez’s Requests for Admission — |Set One, dated December 19, 2022. 5 112. LVMPD’S Responses to Robert O’Brien’s Requests for Admission — Set 6 | |One, dated December 19, 2022. 7 113. LVMPD’S Responses to Alison Kenady’s Requests for Admission — Set 8 | |One, dated December 19, 2022. 9 114. LVMPD’S Responses to Robert O’Brien’s Interrogatories — Set One, dated 10 | |December 19, 2022. 11 115. LVMPD’S Responses to Alison Kenady’s Requests for Production — Set 12 | |One, dated December 20, 2022. 13 116. LVMPD’S Responses to Robert O’Brien’s Requests for Production — Set : 14 | |One, dated December 20, 2022. i ge: 15 117. LVMPD’s Responses to Soldadera Sanchez’ Requests for Production — Set 16 | |One, dated December 20, 2022. 17 118. LVMPD’S Responses to Tenisha Martin’s Requests for Production — Set 18 | |One, dated December 20, 2022. 19 119. LVMPD’S Responses to Alison Kenady’s Interrogatories — Set Two, dated 20 | |January 4, 2023. 21 120. LVMPD’S Responses to Robert O’Brien’s Interrogatories — Set Three, 22 | |dated January 4, 2023. 23 121. LVMPD’S Responses to Alison Kenady’s Interrogatories - Set Two, dated 24 | |January 4, 2023. 25 122. LVMPD’S Responses to Robert O’Brien’s Interrogatories - Set Three, 26 | |dated January 4, 2023. 27 123. LVMPD’s Ninth Supplemental Disclosure of Witnesses and Documents 28 | |Pursuant to FRCP 26.1(a)(1), dated February 16, 2023. 20 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST ] 124. LVMPD’s First Supplemental Answers to Plaintiff Robert O’Brien’s First 2 | |Set of Interrogatories, dated February 16, 2023. 3 125. LVMPD’s First Supplemental Answers to Plaintiff Soldadera Sanchez’s 4 | |Second Set of Interrogatories, dated February 16, 2023. 5 126. LVMPD’s Third Supplemental Responses to Plaintiffs’ First Set of 6 | |Requests for Production of Documents, dated February 16, 2023. 7 127. LVMPD’s Second Supplemental Responses to Plaintiff's Second Set of 8 | |Requests for Production of Documents, dated February 16, 2023. 9 128. LVMPD’s First Supplemental Responses to Plaintiffs’ Sixth Set of 10 | |Requests for Production of Documents, dated February 16, 2023. 11 129. LVMPD’S Responses to Plaintiff Tenisha Martin’s Requests for Production 12 | }of Documents - Set One [sic Set Two], dated February 16, 2023. 13 130. LVMPD’s Tenth Supplemental Disclosure of Witnesses and Documents : 14 | |Pursuant to FRCP 26.1(a)(1), dated February 24, 2023. i ge: 15 131. LVMPD’s Responses to Tenisha Martin’s Requests for Production □□ 4 16 | |Documents - Set Three dated May 22, 2023. 17 132. LVMPD’s Responses to Gabriela Molina’s Requests for Admissions - Set 18 | |Two dated July 17, 2023. 19 133. LVMPD’s Responses to Lance Downes-Covington’s Requests for 20 | |Production of Documents - Set Two dated July 17, 2023. 21 134. LVMPD’s Eleventh Supplemental Disclosure of Witnesses and Documents 22 | |Pursuant to FRCP 26.1(a)(1), dated July 17, 2023. 23 135. LVMPD’s Twelfth Supplemental Disclosure of Witnesses and Documents 24 | |Pursuant to FRCP 26.1(a)(1), dated April 24, 2024. 25 %6 C. DEPOSITIONS. 7 1. LVMPD Defendants deposed Plaintiff Alison Kenady on August 9, 2022. 3g 2. LVMPD Defendants deposed Plaintiff Gabriela Molina on August 10, 2022. 2] STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 3. LVMPD Defendants deposed Plaintiff Emily Driscoll on August 11, 2022. 2 4. LVMPD Defendants deposed Plaintiff Tenisha Martin on August 16, 2022. 3 5. LVMPD Defendants deposed Plaintiff Lance Downes-Covington on August 19, 4} |2022. 5 6. LVMPD Defendants deposed Plaintiff Soldadera Sanchez on August 20, 2022. 6 7. Plaintiffs deposed Defendant Officer Jordan Turner on October 18, 2022. 7 8. Plaintiffs deposed Defendant Officer Tabatha Dickson on October 24, 2022. 8 9. Plaintiffs deposed Defendant Officer Evan Spoon on November 7, 2022. 9 10. Plaintiffs deposed Defendant Retired Captain Patricia Spencer on November 15, 10 | |2022. 11 11. Plaintiffs deposed Defendant Captain Dori Koren on November 22, 2022. 12 12. Plaintiffs deposed Defendant Lt. Kurt McKenzie on December 21, 2022. 13 13. LVMPD Defendants deposed Plaintiff Robert O’Brien on March 24, 2023. 14 14. Plaintiffs deposed LVMPD Defendants’ FRCP 30(b)(6) designee(s) - Lt. Landon i ge: 15 | |Reyes on June 20, 2023. a 16 15. Plaintiffs’ Deposition Subpoena to Las Vegas Justice Court per FRCP 30(b)(6) for 17 | |records related to Defendants’ citations and arrests during the 2020 BLM Protests. 18 16. Plaintiffs’ Deposition Subpoena to Las Vegas Municipal Court per FRCP 30(b)(6) 19 | |for records related to Defendants’ citations and arrests during the 2020 BLM Protests. 20 17. Plaintiffs deposed Defendants’ FRCP 30(b)(6) designee(s) (Dori Koren) on April 21 | |26, 2024. 22 18. Plaintiffs will be deposing Defendants’ FRCP 30(b)(6) designee(s) (John 23 | |McGrath) in August or September 2024 24 | |II. DISCOVERY THAT REMAINS TO BE COMPLETED. 25 The Parties are actively conducting discovery and have completed the majority of 26 | |the written discovery and depositions. However, the Parties are continuing to meet and confer 27 | \on outstanding discovery issues. 28 22 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 The Parties’ primary remaining discovery tasks include: (1) Plaintiffs have 2 | |subpoenaed records from the Las Vegas Municipal Court and Las Vegas Justice Court for |documents concerning Defendant’s misdemeanor citations and arrests during the BLM 4 | |Protests in 2020 and are in the process of obtaining records related to the same; (2) resolution 5| lof meet and confer issues and motion practice if needed; (3) Plaintiffs’ deposition of 6 | |Defendant Las Vegas Metropolitan Police Department’s FRCP 30(b)(6) designee John 7 | |McGrath; (4) expert disclosures; (5) rebuttal reports; and (6) depositions of the experts. 8 | TIT. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY. 9 This is the sixteenth request for an extension of discovery deadlines in this matter. 10 | |The Parties request that the Discovery Plan and Scheduling Order deadlines be extended an 11 | additional forty-five (45) days so that the Parties may complete the tasks above and efficiently 12 | |manage expert disclosures. This involves waiting for deposition transcripts requiring 13 | |expert review and analysis and Defendants need to supplement their production of Bates 2 14 | |stamped documents. é 15 The Parties acknowledge that, pursuant to Local Rule 26-3, the Parties must : 16 | Jestablish that good cause exists to extend the deadlines. 17 The Parties have been diligently conducting discovery and continue to conduct 18 | |discovery, but an extension is still needed to efficiently conclude discovery and manage the 19 | |case. 20 Additionally, the parties are continuing to meet and confer with Defendants’ 21 | |counsel regarding the FRCP 30(b)(6) deposition and subpoenas. Meet and confer efforts are 22 | longoing. Likewise, the experts retained in this matter will also need to review the recent 23 | |discovery responses, Defendants’ supplemental responses (if any), information and 24 | |documents in response to Plaintiffs’ subpoenas to Justice Court and Municipal Court, BWC 25 | |videos, and all deposition transcripts, including the two FRCP 30(b)(6) designees—Dori 26 | |Koren and John McGrath. While Dori Koren was deposed on April 26, 2024, the deposition 27 | |transcript is currently pending. Counsel are conferring to schedule a deposition date for John 28 | |McGrath for August or September 2024 due to the schedule conflicts of counsel and the 23 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 | |designees. This deposition will occur after the current deadline for initial expert disclosures. 2||The Parties are working with their respective experts to prepare their expert disclosures. 3 | |However, as noted, the Parties contend that it is more efficient to allow further discovery to |be completed before initial expert disclosures to minimize the need for supplementation. 5 Counsel for Plaintiffs have been required to spend time out of the office 6 | |(and/or out of the jurisdiction) in May, June and July to attend to family obligations. |Mr. Wolpert’s father—who lived out of the jurisdiction in Tucson, Arizona—passed 8 | |away from complications related to amyotrophic lateral sclerosis (ALS) on May 17, 9 | |2024, requiring Mr. Wolpert to assist with funeral arrangements and generally assist 10 | |his widowed mother in Tucson in May and June. Ms. McLetchie’s mother—whom Ms. 11 | |McLetchie had been assisting with care for Stage IV cancer—passed away on July 28, 12 | |2024, requiring Ms. McLetchie to assist with funeral arrangements and attending to 13 | |her late mother’s affairs and estate. Furthermore, Pieter O’Leary, a senior attorney at Hal |McLetchie Law, left the firm effective May 3, 2024, requiring Ms. McLetchie and Mr. é 15 | |Wolpert to devote additional attention to matters in which Mr. O’Leary was lead : 16 | |counsel. 17 The Parties thus respectfully request an extension of time to enable them to conduct 18 | |Inecessary discovery and so that this matter is fairly resolved on the merits. “Good cause to 19 | |extend a discovery deadline exists ‘if it cannot reasonably be met despite the diligence of the 20 | |party seeking the extension.’” Derosa v. Blood Sys., Inc., No. 2:13-cv-0137-JCM-NJK, 2013 21] |U.S. Dist. LEXIS 108235, 2013 WL 3975764, at 1 (D. Nev. Aug. 1, 2013) (quoting Johnson 22 | |v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)); see also Fed. R. Civ. P. 1 23 | |(providing that the Rules of Civil Procedure “should be construed, administered, and employed by the court and the Parties to secure the just, speedy, and inexpensive 25 | |determination of every action and proceeding”). As the procedural history of this case 26 | illustrates, the Parties have been diligent in litigating this matter. Significant written 27 | |discovery has been exchanged, nearly all depositions are complete, experts are engaged, and 28 | |counsel continue to meet and confer regarding various topics. Additionally, counsel for the STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 | |Parties in this matter are litigating several other unrelated matters (including against each 2 | Jother) which have competing demands. While competing demands of litigation are merely 3| Jone of many reasons for the instant request, it should be noted that the other litigation 4 | |between the same counsel involving similar issues can only benefit from the completion of 5 | |discovery in this matter so that in other litigation, similar requests can be expedited and can 6 | |further the resolution of those matters and the interests of justice. Indeed, counsel for the 7 | |Parties continue to engage in settlement discussions regarding this and the other matters they 8 | |are litigating that stem from the BLM protests. 9 | |Thus, the standards to extend all deadlines, including the expert deadlines, is satisfied here. 10 Based on the foregoing stipulation and proposed deadlines, the Parties thus 11 | |respectfully request an extension of time to extend the deadlines in this matter to enable to 12 | |them to conduct necessary discovery and so that this matter is fairly resolved on the merits. ]IV. PROPOSED SCHEDULE FOR REMAINING DEADLINES § 15 Current Deadline Proposed New Deadline 5 16 Amend Pleadings and Add Parties June 14, 2022 Past/Unchanged © || Initial Expert Disclosures August 1, 2024 September 16, 2024! 18 Rebuttal Expert Disclosures September 5, 2024 October 21, 2024? 19 Discovery Cut-Off September 26, 2024 November 11, 2024° November 19,2024 | January 3, 2025 Pretrial Order December 2, 2024 January 16, 2025 71 (If dispositive motions are filed, the deadline for shall be 92 suspended until thirty (30) days after the decision of the 93 dispositive motions or further order of the Court.) 24 Based on the foregoing stipulation and proposed deadlines plan, the Parties request 25 that the Discovery Plan and Scheduling Order deadlines be extended an additional forty-five 26 27) | 45 days after August 1, 2024 is Sunday, September 15, 2024. 28 45 days after September 5, 2024 is Sunday, October 20, 2024. > 45 days after September 26, 2024is Sunday, November 10, 2024. 25 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST 1 | |(45) days so that the Parties may conduct additional discovery, and efficiently manage expert 2 | |disclosures. 3 4 Dated this 31" day of July, 2024. Dated this 31“ day of July, 2024. 5 MCLETCHIE LAW MARQUIS AURBACH 6 By: /s/ Leo S. Wolpert By: /s/ Jackie V. Nichols 7 Margaret A. McLetchie, Esq. Craig R. Anderson, Esq. Nevada Bar No. 10931 Nevada Bar No. 6882 8 Leo S. Wolpert, Esq. Jackie V. Nichols, Esq. Nevada Bar No. 12658 Nevada Bar No. 14246 9 602 South 10th Street 10001 Park Run Drive 10 Las Vegas, Nevada 89101 Las Vegas, Nevada 89145 Attorneys for Plaintiffs Attorneys for Defendants Las Vegas 11 Metropolitan Police Department, Lieutenant Kurt McKenzie, Officer 12 Tabatha Dickson, Captain Patricia 13 Spencer, Captain Dori Koren, Officer Evan Spoon and Officer Jordan Turner 15 ORDER 2435 16 The above Stipulation is hereby GRANTED. 18 IT IS SO ORDERED. CO) 20 UNITED STATES MASISTRATE JUDGE 21 22 DATED: 8/2/2024 23 24 25 26 27 28 26 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — SIXTEENTH REQUEST