1 Marquis Aurbach Craig R. Anderson, Esq. 2 Nevada Bar No. 6882 10001 Park Run Drive 3 Las Vegas, Nevada 89145 Telephone: (702) 382-0711 4 Facsimile: (702) 382-5816 [email protected] 5 Attorneys for Defendants Las Vegas Metropolitan Police Department, Andrew Bauman, Matthew Kravetz, Supreet Kaur, 6 David Jeong, and Theron Young 7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 8 CONNIE SEMPER1, an individual; ASHLEY Case Number: 9 MEDLOCK, an individual; LONICIA 2:20-cv-01875-JCM-EJY BOWIE, an individual; MICHAEL GREEN, 10 an individual; CLINTON REECE, an individual; COREY JOHNSON, an STIPULATION AND ORDER TO 11 individual; DEMARLO RILEY, an EXTEND DEADLINE TO FILE JOINT individual; CORY BASS, an individual; PRETRIAL ORDER 12 CARLOS BASS, an individual; BREANNA NELLUMS, an individual; and ANTONIO (FOURTH REQUEST) 13 WILLIAMS, an individual, 14 Plaintiffs, 15 vs. 16 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; 17 ANDREW BAUMAN, individually and in his capacity as a Las Vegas Metropolitan 18 Police Department Officer; DAVID JEONG, individually and in his capacity as a Las 19 Vegas Metropolitan Police Department Officer; SUPREET KAUR, individually and 20 in his capacity as a Las Vegas Metropolitan Police Department Officer; MATTHEW 21 KRAVETZ, individually and in his capacity as a Las Vegas Metropolitan Police 22 Department Officer; and THERON YOUNG, individually and in his capacity as a Las 23 Vegas Metropolitan Police Department Officer, 24 Defendants. 25 26 27 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. 1 Pursuant to LR 7-1 and LR IA 6-1, Plaintiffs, by and through their attorneys of 2 record, American Civil Liberties Union of Nevada and Defendants, by and through their 3 attorneys of record, Marquis Aurbach, respectfully submit this Stipulation to Extend 4 Deadline to File Joint Pretrial Order, representing their fourth request to extend the 5 aforementioned deadline. Parties are seeking an extension making the new deadline 6 December 5, 2025, to file this Joint Pretrial Order. 7 A stipulation to extend time may be supported by a showing of good cause. FRCP 8 Rule 6; Local Rule 26-3. Good cause is not a rigorous or high standard. Ahanchion v. Xenon 9 Pictures, Inc.,

, 1259 (9th Cir. 2010). 10 Here, there is good cause to extend the deadline because: 11 1. On March 28, 2025, this Court issued its summary judgment order. ECF No. 12 176. 13 2. Following this, the Parties attempted to settle this matter through mediation. 14 3. To provide space for mediation, the Parties filed a Stipulation and Order to 15 extend the time to file the Joint Pretrial Order. ECF No. 180 16 4. After working diligently to determine a mutually agreed upon neutral, the 17 Parties scheduled a private mediation for September 2, 2025, with Hon. Jennifer Togliatti. 18 5. The timing of the scheduled mediation required the Parties to request a 19 second extension to the deadline for the Joint Pretrial Order. ECF No. 181. 20 6. This extension was granted and the new deadline was set to November 3, 21 2025. ECF No. 182. 22 7. In preparation for mediation Parties focused their attention on the mediation, 23 dedicating their time to drafting mediation briefs and preparing their respective clients for 24 mediation. 25 8. On August 29, 2025, LVMPD withdrew from settlement discussions and 26 cancelled the mediation. 27 1 9. On September 15, 2025, Plaintiffs’ counsel contacted Defendants’ counsel to 2 begin preparation on the Joint Pretrial Order. 3 10. On September 18, 2025, Parties met to discuss the drafting of the Joint 4 Pretrial Order. 5 11. On October 3, 2025, Defendants’ counsel provided Plaintiffs’ counsel with a 6 working draft of the Proposed Joint Pretrial Order, including initial drafts for contested and 7 uncontested facts, contested legal issues for trial, and a list of approximately 529 exhibits 8 that Defendants are considering presenting at trial. 9 12. Since receiving the draft Plaintiffs have diligently worked to review and 10 provide objections and grounds for each exhibit, identify the exhibits Plaintiffs may offer for 11 trial based on the claims not resolved through the cross motions for summary judgment, and 12 consider what other relevant facts must be included in the joint trial order. 13 13. Parties needed additional time to negotiate objections and potentially parse 14 down the list of exhibits. 15 14. Parties needed additional time to determine whether the relevant facts have 16 been correctly categorized as contested and uncontested. 17 15. Parties needed additional time to determine whether any motions for 18 clarification may be necessary in regards to the Court’s orders on summary judgment. 19 15. Counsel for Defendants were in a federal court jury trial from October 20, 20 2025 thru November 3, 2025. 21 16. Counsel for Defendants will be out of state for a work-related matter on 22 November 13 and 14, 2025. 23 17. Counsel for Defendants also had a pre-scheduled trip out of the United States 24 scheduled from November 20, 2025 through December 1, 2025. 25 18. No trial dates have yet been set in this matter. 26 / / / 27 / / / 1 19. This Stipulation is brought in good faith and is not intended to delay any 2 adjudication of this matter. 3 IT IS SO STIPULATED this 17th day of November, 2025. 4 MARQUIS AURBACH AMERICAN CIVIL LIBERTIES UNION OF NEVADA 5 By: /s/ Craig R. Anderson By: s/Christopher M. Peterson 6 Craig R. Anderson, Esq. Christopher M. Peterson, Esq. Nevada Bar No. 6882 Nevada Bar No. 13932 7 10001 Park Run Drive Jacob T. S. Valentine, Esq. Las Vegas, Nevada 89145 Nevada Bar No. 16324 8 Attorneys for Defendants 4362 W. Cheyenne Avenue North Las Vegas, Nevada 89032 9 Attorneys for Plaintiffs 10 ORDER 11 12 IT IS SO ORDERED. 13 Date: November 17, 2025 14 15 United States Magistrate Judge 16 17 18 19 20 21 22 23 24 25 26 27