Phillip Semper, Core v. American Civil Liberties Union of Nevada

1 CHRISTOPHER M. PETERSON, ESQ. (NV 13932) JACOB T. S. VALENTINE, ESQ. (NV 16324) AMERICAN CIVIL LIBERTIES UNION OF NEVADA 4362 W. Cheyenne Ave. North Las Vegas, NV 89032 Telephone: (702) 366-1226 Facsimile: (702) 830-9205 Emails: [email protected] [email protected] ROBERT L. LANGFORD, ESQ. (NV 3988) ROBERT L. LANGFORD & ASSOCIATES South Eighth Street Las Vegas, NV 89101 Telephone: (702) 471-6565 Facsimile: (702) 991-4223 Email: [email protected] Attorneys for Plaintiffs Phillip Semper, Corey Jo hnson, Ashley Medlock, Michael Green, Demarlo Riley, Clinton Reece, and Lonicia Bowie UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA Connie Semper1, an individual; Ashley Medlock, an individual; Lonicia Bowie, an Case No.: 2:20-cv-01875-JCM-EJY individual; Michael Green, an individual; Clinton Reece, an individual; Corey Johnson, an individual; Demarlo Riley, an Stipulation and Order to Extend Deadline individual; Cory Bass, an individual; Carlos to File Joint Pretrial Order Bass, an individual; Breanna Nellums, an individual; and Antonio Williams, an (Third Request) individual, Plaintiffs, 19 vs. Las Vegas Metropolitan Police Department, in its official capacity; Andrew Bauman, individually and in his capacity as a Las Vegas Metropolitan Police Department Officer; David Jeong, individually and in his capacity as a Las Vegas Metropolitan Police Department Officer; Supreet Kaur, 1 Pursuant to FRCP 25, Ms. Semper has been substituted for Phillip Semper pursuant to this court’s order date January 13, 2022, as she is the executrix of his estate. individually and in his capacity as a Las Vegas Metropolitan Police Department Officer; Matthew Kravetz, individually and in his capacity as a Las Vegas Metropolitan Police Department Officer; and Theron Young, individually and in his capacity as a Las Vegas Metropolitan Police Department Officer, Defendants.

6 Pursuant to LR 7-1 and LR IA 6-1, Plaintiffs, by and through their attorneys of record, American Civil Liberties Union of Nevada and Defendants, by and through their attorneys of record, Marquis Aurbach, respectfully submit this Stipulation to Extend Deadline to File Joint Pretrial Order, representing their third request to extend the aforementioned deadline. Parties are seeking an extension of 14 days making the new deadline November 17, 2025, to file this Joint Pretrial Order.

12 A stipulation to extend time may be supported by a showing of good cause. FRCP Rule 6; Local Rule 26-3. Good cause is not a rigorous or high standard. Ahanchion v. Xenon Pictures, Inc., 624 F.3d 1253, 1259 (9th Cir. 2010).

15 Here, there is good cause to extend the deadline because: 16 1. On March 28, 2025, this Court issued its summary judgment order. ECF No.176.

17 2. Following this, the Parties attempted to settle this matter through mediation.

18 3. To provide space for mediation, the Parties filed a Stipulation and Order to extend the time to file the Joint Pretrial Order. ECF No. 180 20 4. After working diligently to determine a mutually agreed upon neutral, the Parties scheduled a private mediation for September 2, 2025, with Hon. Jennifer Togliatti.

22 5. The timing of the scheduled mediation required the Parties to request a second extension to the deadline for the Joint Pretrial Order. ECF No. 181.

1 6. This extension was granted and the new deadline was set to November 3, 2025. ECF No. 182.

3 7. In preparation for mediation Parties focused their attention on the mediation, dedicating their time to drafting mediation briefs and preparing their respective clients for mediation.

5 8. On August 29, 2025, LVMPD withdrew from settlement discussions and cancelled the mediation.

7 9. On September 15, 2025, Plaintiffs’ counsel contacted Defendants’ counsel to begin preparation on the Joint Pretrial Order.

9 10.On September 18, 2025, Parties met to discuss the drafting of the Joint Pretrial Order.

10 11.On October 3, 2025, Defendants’ counsel provided Plaintiffs’ counsel with a working draft of the Proposed Joint Pretrial Order, including initial drafts for contested and uncontested facts, contested legal issues for trial, and a list of approximately 529 exhibits that Defendants are considering presenting at trial.

14 12.Since receiving the draft Plaintiffs have diligently worked to review and provide objections and grounds for each exhibit, identify the exhibits Plaintiffs may offer for trial based on the claims not resolved through the cross motions for summary judgment, and consider what other relevant facts must be included in the joint trial order.

18 13.Parties need additional time to negotiate objections and potentially parse down the list of exhibits.

20 14.Parties need additional time to determine whether the relevant facts have been correctly categorized as contested and uncontested.

22 15.Parties need additional time to determine whether any motions for clarification may be necessary in regards to the Court’s orders on summary judgment.

1 16.Counsel for Defendants had trial for another matter scheduled from October 20, 2025, to November 1, 2025.

3 17.No trial dates have yet been set in this matter.

4 18.This Stipulation is brought in good faith and is not intended to delay any adjudication of this matter.

6 Dated: November 3, 2025 MARQUIS AURBACH AMERICAN CIVIL LIBERTIES UNION 8 OF NEVADA /s/ Craig R. Anderson /s/ Jacob T. S. Valentine Craig R. Anderson, Esq. Jacob T. S. Valentine, Esq.

Nevada Bar No. 6882 Nevada Bar No. 16324 10001 Park Run Drive 4362 W. Cheyenne Avenue Las Vegas, Nevada 89145 North Las Vegas, Nevada 89032 Attorneys for Defendants Attorneys for Plaintiffs Order IT IS SO ORDERED.

Date: November 3, 2025 20 United States Magistrate Judge