LEONARD T. FINK, ESQ. 1 Nevada Bar No. 6296 2 NAKESHA S. DUNCAN-PEREZ, ESQ. Nevada Bar No. 11556 3 SPRINGEL & FINK LLP 9075 West Diablo Drive, Suite 302 4 Las Vegas, Nevada 89148 5 Telephone: (702) 804-0706 E-Mail: [email protected] 6 [email protected] [email protected] 7

8 Attorneys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; 9 MARCO SOLORIO; and LEONARD MORRIS

10

11 UNITED STATES DISTRICT COURT

12 DISTRICT OF NEVADA

13 MACK MILLER, an individual; Case No.: 2:23-cv-00070-CDS-DJA

14 Plaintiff, STIPULATION AND ORDER TO EXTEND 15 DISCOVERY DEADLINES vs. 16 [EIGHTH REQUEST] CLARK COUNTY, NEVADA, a political 17 subdivision; DOE CLARK COUNTY OFFICERS, in 18 their personal capacities; DOE PRIVATE SECURITY GUARDS, in their personal capacities; 19 PREVENTIVE MEASURES SECURITY FIRM, LLC, a domestic limited liability company; MARCO 20 SOLORIO, individually; LEONARD MORRIS, 21 individually; ROE PRIVATE SECURITY COMPANY; DOES 1 through 20; ROE BUSINESS 22 ENTITIES 1 through 20, inclusive jointly and 23 severally,

24 Defendants.

25 CLARK COUNTY, a Political Subdivision of State of Nevada, 26

27 Cross-Claimant,

28 vs. 1 PREVENTIVE MEASURES SECURITY FIRM, 2 LLC, a domestic limited liability Company, 3 Cross-Defendant. 4

5 IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, and by and 6 through their respective counsel, that the discovery deadlines shall be extended in this matter. 7 I. DISCOVERY COMPLETED TO DATE 8 The parties have participated in the following discovery to date: 9 1. Plaintiff’s FRCP 26(a)(1) Initial Disclosures; 10 2. Plaintiff’s FRCP 26(a)(1) First Supplemental Disclosures; 11 3. Plaintiff’s FRCP 26(a)(1) Second Supplemental Disclosures; 12 4. Plaintiff’s FRCP 26(a)(1) Third Supplemental Disclosures; 13 5. Plaintiff’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 14 6. Plaintiff’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 15 7. Plaintiff’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 16 8. Plaintiff’s FRCP 26(a)(1) Seventh Supplemental Disclosures; 17 9. Plaintiff’s FRCP 26(a)(1) Eighth Supplemental Disclosures; 18 10. Defendant Clark County’s FRCP 26(a)(1) Initial Disclosures; 19 11. Defendant Clark County’s FRCP 26(a)(1) First Supplemental Disclosures; 20 12. Defendant Clark County’s FRCP 26(a)(1) Second Supplemental Disclosures; 21 13. Defendant Clark County’s FRCP 26(a)(1) Third Supplemental Disclosures; 22 14. Defendant Preventive Measures’ FRCP 26(a)(1) Initial Disclosures; 23 15. Defendant Preventive Measures’ FRCP 26(a)(1) First Supplemental Disclosures; 24 16. Defendant Preventive Measures’ FRCP 26(a)(1) Second Supplemental Disclosures; 25 17. Defendant Preventive Measures’ FRCP 26(a)(1) Third Supplemental Disclosures; 26 18. Defendant Clark County’s First Set of Requests for Admissions to Preventive Measures; 27 28 1 19. Defendant Clark County’s First Set of Requests for Production of Documents to Preventive 2 Measures; 3 20. Defendant Clark County’s First Set of Interrogatories to Preventive Measures; 4 21. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for 5 Admissions; 6 22. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of Requests for 7 Production of Documents; 8 23. Defendant Preventive Measures’ Response to Defendant Clark County’s First Set of 9 Interrogatories; 10 24. Defendant Clark County’s First Set of Interrogatories to Plaintiff; 11 25. Defendant Clark County’s First Set of Requests for Admissions to Plaintiff; 12 26. Defendant Clark County’s First Set of Requests for Production of Documents to Plaintiff; 13 27. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for 14 Admissions; 15 28. Plaintiff’s Responses to Defendant Clark County’s First Set of Requests for Production of 16 Documents; 17 29. Plaintiff’s Responses to Defendant Clark County’s First Set of Interrogatories; 18 30. Defendant Preventive Measures’ First Set of Interrogatories to Plaintiff; 19 31. Defendant Preventive Measures’ First Set of Requests for Admissions to Plaintiff; 20 32. Defendant Preventive Measures’ First Set of Requests for Production of Documents to Plaintiff; 21 33. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Admissions; 22 34. Plaintiff’s Responses to Defendant Preventive Measures First Set of Requests for Production of 23 Documents; 24 35. Plaintiff’s Responses to Defendant Preventive Measures First Set of Interrogatories; 25 36. Plaintiff’s First Set of Interrogatories to Defendant Preventive Measures; 26 37. Plaintiff’s First Set of Requests for Admissions to Defendant Preventive Measures; 27 38. Plaintiff’s First Set of Requests for Production to Defendant Preventive Measures; 28 39. Plaintiff’s First Set of Interrogatories to Defendant Clark County; 1 40. Plaintiff’s First Set of Requests for Admissions to Defendant Clark County; 2 41. Plaintiff’s First Set of Requests for Production to Defendant Clark County; 3 42. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Requests for Admissions to 4 Defendant Preventive Measures; 5 43. Defendant Clark County’s Responses to Plaintiff’s First Set of Interrogatories to Defendant Clark 6 County; 7 44. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Admissions to 8 Defendant Clark County; 9 45. Defendant Clark County’s Responses to Plaintiff’s First Set of Requests for Production to 10 Defendant Clark County; 11 46. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Interrogatories and Request 12 for Production; 13 47. Deposition of Plaintiff (completed February 21, 2024); 14 48. Deposition of Kate Murray (completed February 15, 2024); 15 49. Deposition of Brian Cooperman (completed February 15, 2024); 16 50. Deposition of Elando Johnson (completed February 15, 2024); 17 51. Plaintiff’s FRCP 26(a)(1) Ninth Supplemental Disclosures; 18 52. Defendant Clark County’s FRCP 26(a)(1) Fourth Supplemental Disclosures; 19 53. Defendant Clark County’s FRCP 26(a)(1) Fifth Supplemental Disclosures; 20 54. Defendant Clark County’s FRCP 26(a)(1) Sixth Supplemental Disclosures; 21 55. Defendant Preventive Measures’ FRCP 26(a)(1) Fourth Supplemental Disclosures; 22 56. Defendant Preventive Measures’ FRCP 26(a)(1) Fifth Supplemental Disclosures; 23 57. Defendant Preventive Measures’ FRCP 26(a)(1) Sixth Supplemental Disclosures; 24 58. Defendant Preventive Measures’ FRCP 26(a)(1) Seventh Supplemental Disclosures; 25 59. Plaintiff’s FRCP 26(a)(1) Tenth Supplemental Disclosures; 26 60. Deposition of Chief James Rogers (completed on May 9, 2024); 27 61. Deposition of Defendant Clark County’s FRCP 30(b)(6) designee(s) (completed on June 11, 2024); 28 1 62. Deposition of David Sutton/FRCP 30(b)(6) designee(s) for Defendant Preventive Measures 2 (completed June 27, 2024). 3 63. Defendant Preventive Measures’ Responses to Plaintiff’s First Set of Requests for Production 4 (completed July 18, 2024); 5 64. Defendant Clark County’s Eighth Supplemental FRCP 26 Disclosure and Production of 6 Documents (completed July 31, 2024); 7 65. Defendant Clark County’s Supplemental Answers to Plaintiff’s First Set of Interrogatories 8 (completed August 1, 2024); 9 66. Defendant Clark County’s Supplemental Responses to Plaintiff’s First Set of Requests for 10 Production of Documents (completed August 1, 2024); 11 67. Plaintiff’s Initial Designation of Expert Witnesses (completed August 15, 2024); 12 68. Plaintiff’s FRCP 26(a)(1) Eleventh Supplemental disclosures (completed September 3, 2024); 13 69. Inspection of the area of the subject incident at The Clark County Government Center (completed 14 September 4, 2024); 15 70. Plaintiff noticed the deposition of Preventive ex-employee Defendant Marco Solorio for 16 September 20, 2024; 17 71. Defendant Preventive Measures noticed the Rule 35 Exam of Incarcerated Plaintiff, Mack Miller 18 (occurred October 11, 2024); 19 72. Defendant Preventative Measures Eighth Supplemental Disclosures (completed November 6, 20 2024); 21 73. Defendant Preventative Measures Ninth Supplemental Disclosures (completed November 12, 22 2024); 23 74. Defendant Preventative Measures Initial Expert Disclosures (completed November 12, 2024); 24 75. Plaintiff’s Noticed Deposition of Leonard Morris (completed November 13, 2024); 25 76. Plaintiff’s FRCP 26(a)(1) Twelfth Supplemental disclosures (completed November 14, 2024); 26 77. Defendant Preventative Measures Tenth Supplemental Disclosures (completed December 17, 27 2024); 28 78. Defendant Preventative Measures Rebuttal Expert Disclosures (completed December 17, 2024). 1 79. Defendant Preventative Measures Eleventh Supplemental Disclosures (completed February 2 24, 2025); 3 80. Defendant Preventative Measures Twelfth Supplemental Disclosures (completed March 5, 4 2025); 5 81. Plaintiff’s FRCP 26(a)(1) Thirteenth Supplemental disclosures (completed January 28, 6 2025); 7 82. Defendant Preventive Measures Noticed Deposition of Mark Meredith (completed January 8 30, 2025); and 9 83. Plaintiff’s Noticed Deposition of Steve Kaufer CPP (completed January 28, 2025); 10 II. DISCOVERY REMAINING TO BE COMPLETED 11 1. Depositions of other fact witnesses present at the County Commission meeting during the subject 12 incident; 13 2. Deposition of parties’ treating physicians and/or experts; 14 3. Any additional discovery that is necessary as the parties proceed through discovery; 15 4. Defendant Preventative Measures Deposition of Judith Leslie (coordination of a date for 16 deposition is currently in process); 17 5. Defendant Preventive Measures Deposition of John DiMuro, MD (coordination of a date for 18 deposition is currently in process; 19 6. Defendant Preventative Measures Noticed Deposition of Adam West, DO, noticed for April 20 30, 2025; and 21 7. Defendant Preventative Measures has outstanding Subpoenas duces tecum for records that it has 22 not received as of the date of this Stipulation. 23 III. REASONS WHY DISCOVERY NOT COMPLETED WITHIN TIME SET BY 24 DISCOVERY PLAN 25 A motion to extend deadlines articulated in the Court’s Scheduling Order must be supported by a 26 showing of good cause. See Local Rule 26-3; see also Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992). Good cause to extend a deadline exists if it cannot reasonably be met despite 28 the diligence of the party seeking extension. Johnson,

. In the instant matter, all parties 1 have diligently attempted to comply with the Court’s Scheduling Order – however, the parties have 2 determined they require additional time to obtain and produce key evidence related to the incident and 3 alleged damages. Without this necessary evidence the parties’ experts are likely deprived the ability to 4 formulate their opinions, complete their evaluations and prepare their reports accordingly, as well as 5 impairs counsels’ ability to reach a proper determination as to further discovery needed. 6 On July 2, 2024, the parties entered a stipulation to extend the discovery deadlines primarily based 7 on the need for additional time to take depositions, due to new counsel recently associating in for 8 Preventative Measures. Since that time, a Substitution of Counsel for Preventive Measures, Marco Solorio, 9 and Leonard Morris [ECF No. 45] was filed with the Court on September 5, 2024. The parties diligently 10 completed additional written discovery, a couple depositions and a site inspection since the last stipulation. 11 During that time, in addition Preventive Measures completed its Rule 35 medical exam of Plaintiff, Mack 12 Miller, who is currently incarcerated at Three Lakes Valley Conservation Camp at Southern Desert 13 Correctional Center. Preventative measures has disclosed the Rule 35 medical report to all parties. 14 On January 22, 2025, the parties entered into a further Stipulation to extend discovery deadlines, 15 due to Preventative coordinating dates for the depositions of fact witnesses. The parties have limited 16 contact information for these witnesses, therefore it has taken additional time to secure depositions with 17 them. Preventative now has the deposition dates secured, but additional time is needed for the depositions. 18 On April 18, 2025, the parties entered into a further Stipulation to extend the dispositive motion 19 deadline, due to Preventative coordinating dates for the depositions of fact witnesses. The parties have 20 limited contact information for these witnesses, therefore Preventative requires additional time to secure 21 depositions with them. Preventative had the deposition dates secured, but a change in circumstances 22 required the dates to be rescheduled. Preventive is currently coordinating available dates with all counsel 23 and witnesses. The remaining witness depositions and expert depositions will be critical to the claims and 24 defenses in the instant action and will have a direct impact on the opinions of the parties’ retained experts. 25 Accordingly, the parties respectfully request that the dispositive motion deadline be extended an 26 additional Sixty (60) days. The requested extension will ensure all parties have a full and fair opportunity 27 to litigate the claims and defenses on the merits. Therefore, and as set forth below, due diligence and good 28 cause can be shown to allow the Court, in its discretion, to extend the remaining deadline as requested. 1 IV. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 2 Based on the foregoing, the proposed schedule for completing discovery is as follows:

3 Discovery Deadline Current Deadline Proposed Deadline Close of Discovery 3/22/2025 5/20/2025 4 Dispositive Motions 4/24/2025 6/30/2025 5

6 DATED this 18th of April 2025. DATED this 18th of April 2025.

7 SPRINGEL & FINK LLP RICHARD HARRIS LAW FIRM

8

9 By: /s/ Nakesha S. Duncan-Perez By: /s/ Jonathan B. Lee (w/permission) . . LEONARD T. FINK, ESQ. JONATHAN B. LEE, ESQ. 10 Nevada Bar No. 6296 Nevada Bar Number 13524 NAKESHA S. DUNCAN-PEREZ, ESQ. 801 South Fourth Street 11 Nevada Bar No. 11556 Las Vegas, Nevada 89101 12 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 Attorneys for Plaintiff, 13 MACK MILLER 14 Attorneys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY 15 FIRM, LLC; MARCO SOLORIO; and LEONARD MORRIS 16

17 DATED this 18th of April 2025.

18 CLARK COUNTY DISTRICT ATTORNEY 19

20 By: /s/ Joel K. Browning (w/permission) . JOEL K. BROWNING, ESQ. 21 Nevada Bar No. 14489 22 500 South Grand Central Parkway, Ste. 5075 Las Vegas, Nevada 89155 23 Attorneys for Defendant/Cross-Claimant, 24 CLARK COUNTY, NEVADA 25

26

27 28 Mack Miller v Clark County, NV, et al. 1 Case No. 2:23-cv-00070-CDS-DJA Stipulation and Order to Extend Discovery 2 Deadlines (Eighth Request) 3 4 ORDER 5 Pursuant to the Stipulation of the parties and good cause appearing, the discovery deadlines are 6 || extended as follows: 7 Discovery Deadline | Current Deadline | Proposed Deadline 8 Close of Discove 3/22/2025 5/20/2025 9 4/24/2025 6/30/2025 10 |! IT IS SO ORDERED. 11

13 14 15 16 UNITED STATESJMAGISTRATE JUDGE 17 +g || Respectfully submitted, 19 SPRINGEL & FINK LLP 20 21 || By: /s/ Nakesha S. Duncan-Perez LEONARD T. FINK, ESQ. 22 Nevada Bar No. 6296 53 NAKESHA S. DUNCAN-PEREZ, ESQ. Nevada Bar No. 11556 24 9075 West Diablo Drive, Suite 302 Las Vegas, Nevada 89148 25 26 Attomeys for Defendants/Cross-Defendants, PREVENTIVE MEASURES SECURITY FIRM, LLC; 27 MARCO SOLORIO; and LEONARD MORRIS 28

From: Joel Browning <[email protected]> Sent: Friday, April 18, 2025 2:05 PM To: Phaedra L. Calaway <pcalaway @springelfink.com>; Jonathan Lee <[email protected]> Cc: Nakesha Duncan-Perez <[email protected]>; Leonard Fink <[email protected]> Subject: Re: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. You may affix my signature. Thanks. Get Outlook for Android From: Phaedra L. Calaway <[email protected]> Sent: Friday, April 18, 2025 1:57:33 PM To: Jonathan Lee <[email protected]>; Joel Browning <Joel.Browning @clarkcountydanv.gov> Cc: Nakesha Duncan-Perez <[email protected]>; Leonard Fink <[email protected]> Subject: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. CAUTION: This email originated from an External Source. Please use caution before opening attachments, clicking links, or responding to this email. Do not sign-in with your DA account credentials. Dear Counsel, Attached please find for your review a draft of the following document entitled Stipulation and Order to Extend Discovery Deadlines (Eighth Request) (“Stipulation”) for your review. If the Stipulation meets with your approval please advise and if acceptable, please advise if we may execute the Stipulation on your behalf. Should you have any questions regarding the attached please do not hesitate to contact either me or Ms. Duncan-Perez at your earliest convenience so that we may present the Stipulation to the Court. Thank you. Phaedra L. Calaway Legal Assistant to Attorney Nakesha S. Duncan-Perez op wb ate) Woes spb aie AT T O FP BW ET @ ~ T a 9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148 Tel: (702) 804-0706

From: Jonathan Lee <[email protected]> Sent: Friday, April 18, 2025 2:08 PM To: Phaedra L. Calaway <pcalaway @springelfink.com>; [email protected] Cc: Nakesha Duncan-Perez <[email protected]>; Leonard Fink <[email protected]> Subject: Re: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. You may affix mine as well. Jonathan Lee Lawyer - Partner Direct (702) 444-4429

Las Vegas Reno 801 South 4th Street 6900 S. McCarran Blvd., #1010 Las Vegas NV 89101 Reno NV 89509 Ph. (702) 444-4444 x 229 Ph. (775) 222-2222

Legal Disclaimer From: Phaedra L. Calaway <[email protected]> Sent: Friday, April 18, 2025 1:57 PM To: Jonathan Lee <[email protected]>; [email protected] <joel.browning @clarkcountyda.com> Cc: Nakesha Duncan-Perez <[email protected]>; Leonard Fink <[email protected]> Subject: Miller, Mack v. Clark County, Nevada, at al. - (Draft) Stipulation and Order to Extend Discovery Deadlines (Eighth Request); Our Clients: Miller, Mack v. Clark County, Nevada, at al. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear Counsel, Attached please find for your review a draft of the following document entitled Stipulation and Order to Extend Discovery Deadlines (Eighth Request) (“Stipulation”) for your review. If the Stipulation meets with your approval please advise and if acceptable, please advise if we may execute the Stipulation on your behalf.

Should you have any questions regarding the attached please do not hesitate to contact either me or Ms. Duncan-Perez at your earliest convenience so that we may present the Stipulation to the Court. Thank you. Phaedra L. Calaway Legal Assistant to Attorney Nakesha S. Duncan-Perez ro) oun atexc) Arcee bb a=

9075 W. Diablo Drive., Suite 302 | Las Vegas, NV 89148 Tel: (702) 804-0706 | Fax: (702) 804-0798