Downes-Covington v. Las Vegas Metropolitan Police Department

1) MARGARET A. MCLETCHIE, Nevada Bar No. 10931 | | PIETER M. O’LEARY, Nevada Bar No. 15297 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 1) KENADY, an individual, TENISHA MARTIN, | EXTEND DEADLINE FOR 12||an individual GABRIELA MOLINA, an| REPLY INSUPPORT OF individual, MOTION FOR LEAVE TO 13 Plaintiffs, AMEND 14 vs: (THIRD REQUEST) 15||LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; 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 FOR REPLY IN SUPPORT OF MOTION FOR LEAVE TO AMEND — THIRD REQUEST 1 Plaintiffs Lance Downes-Covington, Soldadera Sanchez, Robert O’Brien, Emily Driscoll, Alison Kenady, Tenisha Martin, and Gabriela Molina (collectively “Plaintiffs”’), by and through their respective counsel, and Defendants, the Las Vegas Metropolitan | Police Department (“LVMPD”), Lieutenant Kurt McKenzie, Officer Tabatha Dickson, Captain Patricia Spencer, Captain Dori Koren, Evan Spoon, Jordan Turner, and Unknown | |Officers 1-14 (collectively “LVMPD Defendants”), by and through their respective | | counsel,(collectively the “Parties”) hereby stipulate to the following: 8 1. The Parties agree that the deadline to file a Reply in Support of Plaintiffs’ Motion | |for Leave to Amend shall be rescheduled from February 27, 2023, to March 6, 2023.

10 2. This is the third request for an extension of this deadline.

11 3. The parties met and conferred by telephone on Saturday, February 11, 2023, to | |discuss on-going discovery issues and Defendants’ production of documents / supplemental g 13 | |discovery responses. : 2 14 4. Counsel for Plaintiffs initiated this request due to scheduling conflicts that limits | |their ability to timely and adequately respond to Defendants’ Opposition, including, but not | {limited to, oral argument before the Nevada Supreme Court on March 2, 2023, and an urgent | jongoing medical emergency in counsel’s immediate family requiring immediate time and | Jattention.

19 5. The Parties both submit that the instant stipulation is being offered in good faith | |and not for the purpose of delay.

21 | |/// | |/// | |/// | |/// | |/// | |/// | |/// | |/// pa STIPULATION AND ORDER TO EXTEND DEADLINE FOR REPLY IN SUPPORT OF MOTION FOR LEAVE TO AMEND — THIRD REQUEST 1 IT IS SO STIPULATED.

2 Dated this 27" day of February, 2023. Dated this 27" day of February, 2023.

4 MCLETCHIE LAW GROUP, PLLC MARQUIS AURBACH 5 By: /s/ Pieter M. O'Leary By: /s/ Jackie V. Nichols Margaret A. McLetchie, Esq. Craig R. Anderson, Esq.

6 Nevada Bar No. 10931 Nevada Bar No. 6882 Pieter M. O’Leary, Esq. Jackie V. Nichols, Esq.

7 Nevada Bar No. 15297 Nevada Bar No. 14246 8 Leo S. Wolpert, Esq. 10001 Park Run Drive Nevada Bar No. 12658 Las Vegas, Nevada 89145 9 602 South 10th Street Attorneys for LVMPD Defendants Las Vegas, Nevada 89101 10 Attorneys for Plaintiffs 11 ORDER 12 IO XN) e 13 >< . Ss DANIEL J. ALBREGTS 14 UNITED STATES MAGISTRATE JUDGE DATED: March 1, 2023 ging 16 © 17 STIPULATION AND ORDER TO EXTEND DEADLINE FOR REPLY IN SUPPORT OF MOTION FOR LEAVE TO AMEND — THIRD REQUEST