Semper et al v. Las Vegas Metropolitan Police Department et al, No. 2:2020cv01875 - Document 131 (D. Nev. 2024)
Court Description: ORDER granting 130 Stipulation TO EXTEND DISPOSITIVE MOTIONS DEADLINE (TENTH REQUEST). Motions due by 3/15/2024. Proposed Joint Pretrial Order due by 4/11/2024. Signed by Magistrate Judge Elayna J. Youchah on 3/12/2024. (Copies have been distributed pursuant to the NEF - CAH)
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Semper et al v. Las Vegas Metropolitan Police Department et al Doc. 131 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 1 Marquis Aurbach Craig R. Anderson, Esq. 2 Nevada Bar No. 6882 Jackie V. Nichols, Esq. 3 Nevada Bar No. 14246 10001 Park Run Drive 4 Las Vegas, Nevada 89145 Telephone: (702) 382-0711 5 Facsimile: (702) 382-5816 canderson@maclaw.com 6 jnichols@maclaw.com Attorneys for Defendants Las Vegas Metropolitan 7 Police Department, Andrew Bauman, Matthew Kravetz, Supreet Kaur, David Jeong, and Theron Young 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 CONNIE SEMPER1, an individual; ASHLEY MEDLOCK, an individual; LONICIA 11 BOWIE, an individual; MICHAEL GREEN, an individual; CLINTON REECE, an 12 individual; COREY JOHNSON, an individual; DEMARLO RILEY, an 13 individual; CORY BASS, an individual; CARLOS BASS, an individual; BREANNA 14 NELLUMS, an individual; and ANTONIO WILLIAMS, an individual, 15 Plaintiffs, 16 vs. Case Number: 2:20-cv-01875-JCM-EJY STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTIONS DEADLINE (TENTH REQUEST) 17 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; 18 ANDREW BAUMAN, individually and in his capacity as a Las Vegas Metropolitan 19 Police Department Officer; DAVID JEONG, individually and in his capacity as a Las 20 Vegas Metropolitan Police Department Officer; SUPREET KAUR, individually and 21 in his capacity as a Las Vegas Metropolitan Police Department Officer; MATTHEW 22 KRAVETZ, individually and in his capacity as a Las Vegas Metropolitan Police 23 Department Officer; and THERON YOUNG, individually and in his capacity as a Las 24 Vegas Metropolitan Police Department Officer, 25 Defendants. 26 1 Pursuant to FRCP 25, Ms. Semper has been substituted for Phillip Semper pursuant to this court’s 27 order date January 13, 2022, as she is the executrix of his estate. Page 1 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM Dockets.Justia.com 1 STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTIONS DEADLINE 2 (TENTH REQUEST) 3 The Represented Plaintiffs, Connie Denise Semper, as Special Administrator for the 4 Estate of Phillip Semper, Corey Johnson, Ashley Medlock, Michael Green, Demarlo Riley, 5 Clinton Reece, and Lonicia Bowie (“Plaintiffs”) and Defendants, the Las Vegas Metropolitan 6 Police Department (the “Department” or “LVMPD”), Sheriff Joseph Lombardo 7 (“Lombardo”), Andrew Bauman (“Bauman”), Matthew Kravetz (“Kravetz”), Supreet Kaur 8 (“Kaur”), David Jeong (“Jeong”), and Theron Young (“Young”), collectively (“LVMPD 9 Defendants”), by their respective counsel, hereby stipulate and agree to extend the Discovery 10 Plan and Scheduling Order deadlines an additional 3 days. This Stipulation is being entered 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 in good faith and not for purposes of delay (supplemented information noted in bold-face 12 type). 13 I. STATUS OF DISCOVERY. 14 A. PLAINTIFFS’ DISCOVERY. 15 1. Plaintiffs’ Initial Disclosure of Witnesses and Documents Pursuant to FRCP 16 26.1(a)(1) dated July 6, 2021; 17 2. Plaintiffs’ First Set of Interrogatories to Defendant Andrew Bauman dated July 18 22, 2021; 19 3. Plaintiffs’ First Set of Requests for Production to Defendant Andrew Bauman 20 dated July 22, 2021; 21 4. Plaintiffs’ First Set of Interrogatories to Defendant David Jeong dated July 22, 5. Plaintiffs’ First Set of Requests for Production to Defendant David Jeong dated 22 2021; 23 24 July 22, 2021; 25 6. Plaintiffs’ First Set of Interrogatories to Defendant Supreet Kaur dated July 22, 26 2021; 27 Page 2 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 7. Plaintiffs’ First Set of Requests for Production to Defendant Supreet Kaur 2 dated July 22, 2021; 3 8. Plaintiffs’ First Set of Interrogatories to Defendant Matthew Kravetz dated July 4 22, 2021; 5 9. Plaintiffs’ First Set of Requests for Production to Defendant Matthew Kravetz 6 dated July 22, 2021; 7 10. Plaintiffs’ First Set of Interrogatories to Defendant LVMPD dated July 22, 11. Plaintiffs’ First Set of Requests for Production to Defendant LVMPD dated 8 2021; 9 10 July 22, 2021; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 12. Plaintiffs’ First Set of Interrogatories to Defendant Theron Young dated July 12 22, 2021; 13 13. Plaintiffs’ First Set of Requests for Production to Defendant Theron Young 14 dated July 22, 2021; 15 14. Plaintiffs’ First Supplemental Disclosure of Witnesses and Documents 16 Pursuant to FRCP 26.1(a)(1) dated July 30, 2021; 17 15. Plaintiffs’ Second Set of Interrogatories to LVMPD dated July 30, 2021; 18 16. Plaintiffs’ Second Set of Requests for Production of Documents to LVMPD 19 dated July 30, 2021; 20 17. Plaintiffs' Third Set of Requests for Production to LVMPD dated October 22, 18. Plaintiffs' Fourth Set of Requests for Production of Documents to LVMPD 21 2021; 22 23 dated March 31, 2022; 24 19. Plaintiffs' Second Supplemental FRCP 26.1 Disclosures dated March 31, 2022; 25 20. Plaintiff Corey Johnson's Answers to Defendants' First Set of Requests for 26 Admissions dated April 15, 2022; 27 Page 3 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 21. Plaintiff Corey Johnson's Answers to Defendants' First Set of Interrogatories 2 dated April 15, 2022; 3 22. Plaintiff Connie Semper's Answers to Defendants' First Set of Requests for 4 Admissions dated April 15, 2022; 5 23. Plaintiff Connie Semper's Answers to Defendants' First Set of Interrogatories 6 dated April 15, 2022; 7 24. Plaintiff Michael Green's Answers to Defendants' First Set of Requests for 8 Admissions dated April 15, 2022; 9 25. Plaintiff Michael Green's Answers to Defendants' First Set of Interrogatories 10 dated April 15, 2022; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 26. Plaintiff Ashley Medlock's Answers to Defendants' First Set of Requests for 12 Admissions dated April 15, 2022; 13 27. Plaintiff Ashley Medlock's Answers to Defendants' First Set of Interrogatories 14 dated April 15, 2022; 15 28. Plaintiff Lonicia Bowie's Answers to Defendants' First Set of Requests for 16 Admissions dated April 15, 2022; 17 29. Plaintiff Lonicia Bowie's Answers to Defendants' First Set of Interrogatories 18 dated April 15, 2022; 19 30. Plaintiff Clinton Reece's Answers to Defendants' First Set of Requests for 20 Admissions dated April 15, 2022; 21 31. Plaintiff Clinton Reece's Answers to Defendants' First Set of Interrogatories 22 dated April 15, 2022; 23 32. Plaintiff Demarlo Riley's Answers to Defendants' First Set of Requests for 24 Admissions dated April 15, 2022; 25 33. Plaintiff Demarlo Riley's Answers to Defendants' First Set of Interrogatories 26 dated April 15, 2022; 27 34. Plaintiffs' Third Set of Interrogatories to LVMPD dated February 8, 2023; Page 4 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 35. Plaintiffs' Second Set of Interrogatories to Defendant Andrew Bauman dated 2 February 16, 2023; 3 36. Plaintiffs' First Set of Requests for Admissions to Defendant Andrew Bauman 4 dated February 16, 2023; 5 37. Plaintiffs' Fifth Set of Requests for Production to LVMPD dated February 27, 38. Michael Green's First Amended Answers to LVMPD's First Set of 6 2023; 7 8 Interrogatories dated March 23, 2023; 9 39. Plaintiffs' Third Supplemental FRCP 26.1 Disclosures dated February 27, 11 40. Plaintiffs’ Expert Witness 26.1 FRCP Disclosures dated July 17, 2023; 12 41. Plaintiffs’ Fourth Supplemental FRCP 26.1 Disclosures dated July 31, 2023; 13 42. Plaintiffs' Fourth Set of Interrogatories to LVMPD dated August 9, 2023; 14 43. Plaintiffs' Sixth Set of Requests for Production to LVMPD dated August 9, 44. Plaintiffs' First Set of Requests for Admissions to LVMPD dated August 9, 18 45. Plaintiffs’ Fifth Supplemental FRCP 26.1 Disclosures dated August 24, 2023; 19 46. Corey Johnson's Amended Answers to LVMPD's First Set of Requests for 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 10 2023; 15 2023; 16 17 2023; 20 Admissions dated August 28, 2023; 21 47. Connie Semper's Amended Answers to LVMPD's First Set for Requests for 22 Admissions dated August 29, 2023; 23 48. Demarlo Riley's Amended Answers to LVMPD's First Set for Requests for 24 Admissions dated August 29, 2023; 25 49. Clinton Reece's Amended Answers to LVMPD's First Set for Requests for 26 Admissions dated August 29, 2023; 27 Page 5 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 50. Ashley Medlock's Amended Answers to LVMPD's First Set for Requests for 2 Admissions dated August 29, 2023; 3 51. Michael Green's Amended Answers to LVMPD's First Set for Requests for 4 Admissions dated August 29, 2023; 5 52. Lonicia Bowie's Amended Answers to LVMPD's First Set for Requests for 6 Admissions dated August 29, 2023; 7 53. Plaintiffs’ First Set of Requests for Admission to LVMPD dated November 17, 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 8 2023; and 9 54. Plaintiffs’ Fourth Set of Interrogatories to LVMPD dated November 17, 2023. 10 B. DEFENDANTS’ DISCOVERY. 11 55. LVMPD Defendants’ Initial Disclosure of Witnesses and Documents Pursuant 12 to FRCP 26.1(a)(1) dated July 6, 2021; 13 56. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 14 Andrew Bauman dated August 31, 2021; 15 57. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 16 Defendant Andrew Bauman dated August 31, 2021; 17 58. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 18 David Jeong dated August 31, 2021; 19 59. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 20 Defendant David Jeong dated August 31, 2021; 21 60. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 22 Supreet Kaur dated August 31, 2021; 23 61. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 24 Defendant Supreet Kaur dated August 31, 2021; 25 62. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 26 Matthew Kravetz dated August 31, 2021; 27 Page 6 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 63. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 2 Defendant Matthew Kravetz dated August 31, 2021; 3 64. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 4 LVMPD dated August 31, 2021; 5 65. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 6 Defendant LVMPD dated August 31, 2021; 7 66. Defendant’s Answers to Plaintiffs’ First Set of Interrogatories to Defendant 8 Theron Young dated August 31, 2021; 9 67. Defendant’s Responses to Plaintiffs’ First Set of Requests for Production to 10 Defendant Theron Young dated August 31, 2021; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 68. Defendants’ First Supplemental Disclosure of Witnesses and Documents 12 Pursuant to FRCP 26.1(a)(1) dated August 31, 2021; 13 69. Defendant’s Answers to Plaintiffs’ Second Set of Interrogatories to LVMPD 14 dated September 1, 2021; 15 70. Defendant’s Responses to Plaintiffs’ Second Set of Requests for Production of 16 Records to LVMPD dated September 1, 2021; 17 71. Theron Young's Amended Answers to Plaintiffs' First Set of Interrogatories 18 dated September 8, 2021; 19 72. LVMPD's Amended Answers to Plaintiffs' First Set of Interrogatories dated 20 September 16, 2021; 21 73. LVMPD's Supplemental Responses to Plaintiffs' First Set of Requests for 22 Production dated November 2, 2021; 23 74. LVMPD Defendants' Second Supplemental FRCP 26.1 Disclosures dated 24 November 3, 2021; 25 75. LVMPD's Responses to Plaintiffs' Third Set of Requests for Production dated 26 November 23, 2021; 27 Page 7 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 76. LVMPD Defendants' Third Supplemental FRCP 26.1 Disclosures dated 2 November 23, 2021; 3 77. LVMPD Defendants' Fourth Supplemental FRCP 26.1 Disclosures dated 4 February 3, 2023; 5 78. LVMPD Defendants' Fifth Supplemental FRCP 26.1 Disclosures dated March 6 14, 2022; 7 79. LVMPD Defendants' First Set of Interrogatories to Plaintiff Connie Denise 8 Semper, as Special Administrator for the Estate of Phillip Semper dated March 16, 2022; 9 80. LVMPD Defendants' First Set of Interrogatories to Plaintiff Corey Johnson 10 dated March 16, 2022; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 81. LVMPD Defendants' First Set of Interrogatories to Plaintiff Ashley Medlock 12 dated March 16, 2022; 13 82. LVMPD Defendants' First Set of Interrogatories to Plaintiff Michael Green 14 dated March 16, 2022; 15 83. LVMPD Defendants' First Set of Interrogatories to Plaintiff Demarlo Riley 16 dated March 16, 2022; 17 84. LVMPD Defendants' First Set of Interrogatories to Plaintiff Clinton Reece 18 dated March 16, 2022; 19 85. LVMPD Defendants' First Set of Interrogatories to Plaintiff Lonicia Bowie 20 dated March 16, 2022; 21 86. LVMPD Defendants' First Set of Interrogatories to Plaintiff Cory Bass dated 22 March 16, 2022; 23 87. LVMPD Defendants' First Set of Interrogatories to Plaintiff Antonio Williams 24 dated March 16, 2022; 25 88. LVMPD Defendants' First Set of Interrogatories to Plaintiff Breanna Nellums 26 dated March 16, 2022; 27 Page 8 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 89. LVMPD Defendants' First Set of Interrogatories to Plaintiff Carlos Bass dated 2 March 16, 2022; 3 90. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Connie 4 Denise Semper, as Special Administrator for the Estate of Phillip Semper dated March 16, 5 2022; 6 91. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Corey 7 Johnson dated March 16, 2022; 8 92. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Ashley 9 Medlock dated March 16, 2022; 10 93. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Michael 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 Green dated March 16, 2022; 12 94. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Demarlo 13 Riley dated March 16, 2022; 14 95. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Clinton 15 Reece dated March 16, 2022; 16 96. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Lonicia 17 Bowie dated March 16, 2022; 18 97. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Cory 19 Bass dated March 16, 2022; 20 98. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Antonio 21 Williams dated March 16, 2022; 22 99. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Breanna 23 Nellums dated March 16, 2022; 24 100. LVMPD Defendants' First Set of Requests for Admissions to Plaintiff Carlos 25 Bass dated March 16, 2022; 26 101. LVMPD's Responses to Plaintiffs' Fourth Set of Requests for Production dated 27 May 10, 2022; Page 9 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 102. LVMPD Defendants' Sixth Supplemental FRCP 26.1 Disclosures dated May 2 10, 2022; 3 103. LVMPD's Second Supplemental Responses to Plaintiffs' First Set of Requests 4 for Production dated August 16, 2022; 5 104. LVMPD's First Supplemental Responses to Plaintiffs' Third Set of Requests 6 for Production dated August 16, 2022; 7 105. LVMPD Defendants' Seventh Supplemental FRCP 26.1 Disclosures dated 8 August 16, 2022; 9 106. LVMPD Defendants' Eighth Supplemental FRCP 26.1 Disclosures dated 10 December 7, 2022; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 107. LVMPD Defendants' Ninth Supplemental FRCP 26.1 Disclosures dated 12 January 12, 2023; 13 108. LVMPD Defendants' Tenth Supplemental FRCP 26.1 Disclosures dated 14 February 2, 2023; 15 109. LVMPD's Answers to Plaintiffs' Third Set of Interrogatories dated March 20, 110. Andrew Bauman's Answers to Plaintiffs' Second Set of Interrogatories dated 16 2023; 17 18 March 21, 2023; 19 111. Andrew Bauman's Answers to Plaintiffs' First Set of Requests for Admissions 20 dated March 21, 2023; 21 112. LVMPD's Responses to Plaintiffs' Fifth Set of Requests for Production dated 22 April 5, 2023; 23 113. LVMPD Defendants' Eleventh Supplemental FRCP 26.1 Disclosures dated 24 April 5, 2023; 25 114. LVMPD's Answers to Plaintiffs' Fourth Set of Interrogatories dated September 26 27, 2023; 27 Page 10 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 115. LVMPD's Responses to Plaintiffs' Sixth Set of Requests for Production dated 2 September 27, 2023; 3 116. LVMPD's Responses to Plaintiffs' First Set of Requests for Admissions dated 4 September 27, 2023; 5 117. LVMPD Defendants' Twelfth Supplemental FRCP 26.1 Disclosures dated 6 September 27, 2023; 7 118. LVMPD Defendants' Thirteenth Supplemental FRCP 26.1 Disclosures dated 8 October 16, 2023; 9 119. LVMPD Defendants' Fourteenth Supplemental FRCP 26.1 Disclosures dated 10 October 24, 2023; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 120. LVMPD’s Responses to Plaintiffs’ First Set of Requests for Admission 12 December 18, 2023; 13 121. LVMPD’s Answers to Plaintiffs’ Fourth Set of Interrogatories dated December 14 18, 2023; 15 122. LVMPD Defendants' Fifteenth Supplemental FRCP 26.1 Disclosures dated 16 January 12, 2024; and 17 123. LVMPD’s Supplemental Answers to Plaintiffs’ Third Set of 18 Interrogatories dated February 22, 2024. 19 C. DEPOSITIONS. 20 1. Plaintiffs deposed Defendant Officer Andrew Bauman on November 9, 2021. 21 2. Plaintiffs deposed Officer Nicholas Brigandi on April 18, 2022. 22 3. Plaintiffs deposed Det. Blake Walford on May 11, 2022. 23 4. Plaintiffs deposed Defendant Officer Theron Young on May 16, 2022. 24 5. Plaintiffs deposed Defendant Officer Supreet Kaur on August 31, 2022. 25 6. Plaintiffs deposed Defendant Officer Matthew Kravetz on September 6, 2022. 26 7. Plaintiffs deposed FRCP 30(b)(6) of LVMPD (Landon Reyes) on December 27 13, 2022; Page 11 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 8. Plaintiffs deposed FRCP 30(b)(6) of LVMPD (Fred Haas) on January 10, 9. LVMPD Defendants deposed/recorded Non-Appearance of Plaintiff Pro Per 2 2023; 3 4 Cory Bass on March 13, 2023; 5 10. LVMPD Defendants deposed/recorded Non-Appearance of Plaintiff Pro Per 6 Carlos Bass on March 13, 2023; 7 11. LVMPD Defendants deposed/recorded Non-Appearance of Plaintiff Pro Per 8 Breanna Nellums on March 15, 2023; 9 12. LVMPD Defendants deposed/recorded Non-Appearance of Plaintiff Pro Per 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 10 Antonio Williams on March 15, 2023; 11 13. LVMPD Defendants deposed of Plaintiff Michael Green on March 27, 2023. 12 14. LVMPD Defendants deposed of Plaintiff Lonicia Bowie on August 21, 2023; 13 15. LVMPD Defendants deposed of Plaintiff Counnie Walker [Connie Semper] on 14 August 22, 2023; 15 16. LVMPD Defendants deposed of Plaintiff Clinton Reece on August 22, 2023; 16 17. LVMPD Defendants deposed of Plaintiffs’ Expert Ana Muñiz, Ph.D. on 17 August 25, 2023; 18 18. LVMPD Defendants deposed of Plaintiff Corey Johnson on August 28, 2023; 19 19. LVMPD Defendants deposed of Plaintiff Demarlo Riley on September 11, 20. Plaintiffs deposed FRCP 30(b)(6) of LVMPD (Sgt. Shane Price) on September 20 2023; 21 22 29, 2023; and 23 21. LVMPD Defendants competed deposition of Plaintiff Clinton Reece on 24 October 10, 2023. 25 II. DISCOVERY THAT REMAINS TO BE COMPLETED. 26 Discovery is completed. 27 Page 12 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 III. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY. 2 Parties seek (1) a 3 day extension for filing dispositive motions from March 12, 3 2024, to March 15, 2024, and (2) to continue the pretrial order date from April 8, 2024, 4 to April 11, 2024. All other deadlines will not be affected by this extension. 5 Parties acknowledge that a showing of good cause is necessary for any modifications 6 to a scheduling order within 21 days of a deadline being modified. Local Rule 26-3. 7 Counsel for Defendants was in a three-week trial in the Eighth Judicial District Court 8 that completed on March 6, 2024. Additionally, due to the number of parties involved and 9 the complicated nature of the matters, Parties intend to file a motion to exceed page limits, by 10 thirty (30) pages, prior to filing dispositive motions. As a result, the parties need additional 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 time to finalize their motions for summary judgment and gather exhibits related to the same. 12 IV. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DEADLINES 13 14 Amend Pleadings and Add Parties Current Deadline Proposed New Deadline March 18, 2023 Past Due/Unchanged July 17, 2023 Past Due/Unchanged August 16, 2023 Past Due/Unchanged December 18, 2023 Past Due/Unchanged March 12, 2024 March 15, 2024 April 8, 2024 April 11, 2024 (If dispositive motions are filed, the deadline for shall be suspended until thirty (30) days after the decision of the dispositive motions or further order of the Court.) 15 16 Initial Expert Disclosures Rebuttal Expert Disclosures 17 Discovery Cut-Off 18 Dispositive Motions 19 Pretrial Order 20 21 22 23 ... 24 ... 25 ... 26 ... 27 ... Page 13 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM 1 Based on the foregoing stipulation and proposed deadlines plan, the Parties request 2 that the Discovery Plan and Scheduling Order deadlines be extended an additional three (3) 3 days limited to completing disclosure of the remaining interrogatory supplementation and 4 filing dispositive motions. 5 6 Dated this 12th day of March, 2024 Dated this 12th day of March, 2024 7 AMERICAN CIVIL LIBERTIES UNION OF NEVADA MARQUIS AURBACH 8 9 10 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 11 MARQUIS AURBACH IT IS SO STIPULATED. 12 13 14 15 16 17 By: By: /s/ Christopher M. Peterson Christopher M. Peterson, Esq. Nevada Bar No. 13932 Jacob Smith, Esq. Nevada Bar No. 16324 Sadmira Ramic, Esq. Nevada Bar No. 15984 4362 W. Cheyenne Avenue North Las Vegas, Nevada 89032 Attorneys for Plaintiffs Connie Denise Semper, as Special Administrator for The Estate of Phillip Semper, Corey Johnson, Ashley Medlock, Michael Green, Demarlo Riley, Clinton Reece, and Lonicia Bowie /s/ Jackie V. Nichols Craig R. Anderson, Esq. Nevada Bar No. 6882 Jackie V. Nichols, Esq. Nevada Bar No. 14246 10001 Park Run Drive Las Vegas, Nevada 89145 Attorneys for Defendants Las Vegas Metropolitan Police Department, Sheriff Joseph Lombardo, Andrew Bauman, Matthew Kravetz, Supreet Kaur, David Jeong, and Theron Young ORDER 18 19 The above Stipulation is hereby GRANTED. 20 IT IS SO ORDERED: 21 22 ____________________________________ UNITED STATES MAGISTRATE JUDGE 23 DATED: March 12, 2024 24 25 26 27 Page 14 of 15 MAC:14687-296 5411618_1 3/12/2024 1:28 PM
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