Downes-Covington v. Las Vegas Metropolitan Police Department

[MARGARET A. MCLETCHIE, Nevada Bar No. 10931 PIETER M. O’LEARY, Nevada Bar No. 15297 2| |LEO S. WOLPERT, Nevada Bar No. 12658 MCLETCHIE LAW GROUP, PLLC 602 South 10" Street | |Las Vegas, NV 89101 Telephone: (702) 728-5300 / Fax: (702) 425-8220 >| Email: efile @ nvlitigation.com | | Counsel for Plaintiffs 7 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA | | LANCE DOWNES-COVINGTON, an | Case. No.: 2:20-cv-01790-CDS-DJA individual SOLDADERA SANCHEZ, an | | individual, ROBERT O’BRIEN, an individual, EMILY DRISCOLL, an individual, ALISON | STIPULATION AND ORDER TO KENADY, an individual, TENISHA MARTIN, | EXTEND DEADLINE TO 12||an individual GABRIELA MOLINA, RESPOND LVMPD individual, DEFENDANTS’ OBJECTION TO e 13 Plaintiffs, REPORT AND 14 VS. RECOMMENDATION 15||LAS VEGAS METROPOLITAN POLICE | (FIRST REQUEST) DEPARTMENT, in its official capacity; | [ECF No. 99] 2422 16/|LIEUTENANT KURT MCKENZIE, as an 7 individual and in his capacity as a Las Vegas Metropolitan Police Department Officer; 18||OFFICER TABATHA DICKSON, as an individual and in her capacity as a Las Vegas Metropolitan Police Department Officer; CAPTAIN PATRICIA SPENCER, as an individual and in her capacity as a Las Vegas {Metropolitan Police Department Officer; CAPTAIN DORI KOREN, as an individual and | lin his capacity as a Las Vegas Metropolitan Police Department Officer; EVAN SPOON, as an individual and in his capacity as a Las Vegas 24||Metropolitan Police Department Officer; JORDAN TURNER, as an individual and in his capacity as a Las Vegas Metropolitan Police | | Department Officer; UNKNOWN OFFICERS 1- 14, as individuals and in their capacity as Las | | Vegas Metropolitan Police Department Officers, 28 Defendants.

STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION 1 Pursuant to LR JIA 6-1, Plaintiffs LANCE DOWNES-COVINGTON, |SOLDADERA SANCHEZ, ROBERT O’BRIEN, EMILY DRISCOLL, ALISON | |KENADY, TENISHA MARTIN, and GABRIELA MOLINA (collectively “Plaintiffs”) and 4| |Defendants LAS VEGAS METROPOLITAN POLICE DEPARTMENT, LIEUTENANT 5|/KURT MCKENZIE, OFFICER TABATHA DICKSON, CAPTAIN PATRICIA |SPENCER, CAPTAIN DORI KOREN, EVAN SPOON, JORDAN TURNER, and 7| |\UNKNOWN OFFICERS 1-14 (collectively “LVWMPD Defendants”), by and through their | |respective counsel, hereby stipulate and request that this Court extend the deadline to file | |Plaintiffs’ Response to LVMPD Defendants’ Opposition to Report and Recommendation | |CECF No. 99) by an additional 14 days, extending the deadline from October 19, 2022 to | |November 2, 2022. This is the first stipulation for extension of time for Plaintiffs to respond | |to LVMPD Defendants’ Opposition. g 13 This Request for an extension of time is not sought for any improper purpose or : 14 | Jother purpose of delay. This request for extension is based upon the following: 15 Counsel for Plaintiff initiated this request due to their scheduling conflicts | jincluding, but not limited to, Depositions of Defendant Officers Turner (October 18, 2022) | jand Dickson (October 24, 2022) thereby limiting their ability to timely and adequately | |respond to Defendants’ Opposition.

19] | /// 20] | /// /// /// || /// 24] | /// 25] | /// /// | /// | | /// pa STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION 1 WHEREFORE, the parties respectfully request that this Court extend the deadline 2||to file Plaintiffs Response to LVMPD Defendants’ Opposition to Report and | [Recommendation up to and including November 2, 2022.

5 IT IS SO STIPULATED. |DATED this 18" day of October, 2022. DATED this 18" day of October, 2022.

8 MCLETCHIE LAW GROUP, PLLC MARQUIS AURBACH | |4/ Pieter M. O’Leary /s/ Jackie V. Nichols ll Margaret A. McLetchie, NBN 10931 Craig R. Anderson, NBN 6882 Pieter M. O’Leary, NBN 15297 Jackie V. Nichols, NBN 14246 | |Leo S. Wolpert, NBN 12658 10001 Park Run Drive South Tenth Street Las Vegas, NV 89145 & 13 | |Las Vegas, NV 89101 Attorneys for Defendants Las Vegas 44 Attorneys for Plaintiffs Metropolitan Police Department gine 10 18 ORDER IT IS SO ORDERED 20 / ] 21 LZ 3 wT TRICT JUDGE 24 DATED: October 19, 2022 STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION