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, an| OBJECT TO DEFENDANTS’ individual, MOTION TO DISMISS 13 Plaintiffs, OFFICER EVAN SPOON AND 44 VS. OFFICER JORDAN TURNER [ECF No. 106] AND (2) 15||LAS VEGAS METROPOLITAN POLICE | DEFENDANTS’ MOTION FOR DEPARTMENT, in its official capacity; | PARTIAL DISMISSAL OF 16||LIEUTENANT KURT MCKENZIE, as an| OFFICER TABATHA DICKSON 7 individual and in his capacity as a Las Vegas | [ECF No. 108] Metropolitan Police Department Officer; 18||OFFICER TABATHA DICKSON, as an} (FIRST REQUEST) 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 (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN 1 Pursuant to LR JIA 6-1, Plaintiffs LANCE DOWNES-COVINGTON, 2||SOLDADERA SANCHEZ, ROBERT O’BRIEN, EMILY DRISCOLL, ALISON | |KENADY, TENISHA MARTIN, and GABRIELA MOLINA (collectively “Plaintiffs”) and | |Defendants LAS VEGAS METROPOLITAN POLICE DEPARTMENT, LIEUTENANT | |KURT MCKENZIE, OFFICER TABATHA DICKSON, CAPTAIN PATRICIA SPENCER, | |CAPTAIN DORI KOREN, OFFICER EVAN SPOON, OFFICER JORDAN TURNER, and 7| |\UNKNOWN OFFICERS 1-14 (collectively “LVMPD Defendants”), by and through their | |respective counsel, hereby stipulate and request that this Court extend the deadline to file | |Plaintiffs’ Objection to (1) LVMPD Defendants’ Motion to Dismiss Officer Spoon and | |Officer Turner (ECF No. 106) and (2) LVMPD Defendants’ Motion for Partial Dismissal as | |to Officer Dickson (ECF No. 108) by an additional 14 days, extending the deadline from | |October 27, 2022 to November 10, 2022. This is the first stipulation for extension of time for g 13 | |Plaintiffs to Object to LVMPD Defendants’ two Motions to Dismiss.

14 This Request for an extension of time is not sought for any improper purpose or | |other purpose of delay. This request for extension is based upon the following: 16 Counsel for Plaintiff initiated this request due to their scheduling conflicts 17 | jincluding, but not limited to, Depositions of Defendant Officers Turner (October 18, 2022), | |Dickson (October 24, 2022), Spoon (November 7, 2022) as well as the deadline to Respond | |to LVMPD Defendants’ Objection to Report and Recommendation (ECF No. 99) thereby | |limiting their ability to timely and adequately object to LVMPD Defendants’ two Motions. /// /// || /// 24] | /// 25] | /// /// | /// | | /// pa STIPULATION AND ORDER TO (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN 1 WHEREFORE, the parties respectfully request that this Court extend the deadline | |to file Plaintiffs’ Objection to LVMPD Defendants’ two Motions to Dismiss up to and | |including November 10, 2022.

5 IT IS SO STIPULATED.

6 | |DATED this 26" day of October, 2022. DATED this 26" 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 602 South 10" Street Las Vegas, NV 89145 & 13 | |Las Vegas, NV 89101 Attorneys for Defendants Las Vegas 44 Attorneys for Plaintiffs Metropolitan Police Department, et al.

gine 10 © 17 18 ORDER IT IS SO ORDERED.

20 ) 22 [er 3 US. DI TRICT JUDGE 24 DATED: November 1, 2022 STIPULATION AND ORDER TO (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN