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: [email protected] | | Counsel for Plaintiffs 7 UNITED STATES DISTRICT COURT g DISTRICT OF NEVADA g | | 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 FILE 12| {an individual, GABRIELA MOLINA, an| OBJECTIONS TO REPORT AND individual, RECOMMENDATION [ECF NO. 13 Plaintiffs 144] 14 vs. (FIRST REQUEST) 15||LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; 16)|LIEUTENANT KURT MCKENZIE, as an 17 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 in 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 FILE OBJECTIONS TO REPORT AND RECOMMENDATION [ECF NO. 144] — FIRST 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 objections to the Report and | |Recommendation issued April 20, 2023 (ECF No. 144) shall be rescheduled from May 4, | |2023, to May 11, 2023.

11 2. This is the first request for an extension of this deadline.

12 3. Counsel for Plaintiffs initiated this request due to scheduling conflicts that limits | |their ability to timely and adequately lodge objections to the Report and Recommendation, : 14 | |due to an unexpected personal emergency requiring significant time and attention. i 15 4. The Parties both submit that the instant stipulation is being offered in good faith | and not for the purpose of delay.

17 | |/// | |/// | |/// | |/// | | I/// | |/// | | |/// | |/// | |/// | |/// STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE OBJECTIONS TO REPORT AND RECOMMENDATION [ECF NO. 144] — FIRST REQUEST 1 IT IS SO STIPULATED.

2 Dated this 4" day of May, 2023. Dated this 4" day of May, 2023.

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

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

7 Nevada Bar No. 15297 Nevada Bar No. 14246 g 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 1] 12 ORDER - 1B IT IS THEREFORE ORDERED that the stipulation to extend the deadline to file 5 8 14 | objections to the Report and Recommendation issued April 20, 2023, (ECF No. 144) is Ze 15 | granted, nunc pro tunc, to the date of the request. The deadline is extended from May 4, gage 6 | | 2023, to May 11, 2023. ) / = 17 . LZ DATED! STATES DISTRICT JUDGE 19 DATEL May 10, 2023 STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE OBJECTIONS TO REPORT AND RECOMMENDATION [ECF NO. 144] — FIRST REQUEST