1 Marquis Aurbach Craig R. Anderson, Esq. 2 Nevada Bar No. 6882 Andrew Yates, Esq. 3 Nevada Bar No. 17016 10001 Park Run Drive 4 Las Vegas, Nevada 89145 Telephone: (702) 382-0711 5 Facsimile: (702) 382-5816 [email protected] 6 [email protected] Attorneys for Defendants Las Vegas Metropolitan 7 Police Department and Officer Jonathan Grant 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 SHAWN ARMSTRONG, individually, Case Number: 2:25-cv-00862-RFB-DJA 11 Plaintiff, 12 vs. 13 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a political subdivision of 14 the State of Nevada and LVMPD OFFICER J. GRANT, P#19712, 15 Defendants. 16 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND 17 SCHEDULING ORDER DEADLINES 18 (DEFENDANTS’ FIRST REQUEST) 19 Defendants Las Vegas Metropolitan Police Department (the “Department” or 20 “LVMPD”), and Officer Jonathan Grant (“Grant”), (collectively, “LVMPD Defendants”), by 21 and through their counsel of record, Craig R. Anderson, Esq. and Andrew Yates, Esq., of 22 Marquis Aurbach, hereby request to extend the Discovery Plan and Scheduling Order 23 deadlines an additional sixty (60) days. Plaintiff Shawn Armstrong, by and through his 24 attorneys of record, Stephen P. Stubbs, Esq. and Jared R. Richards of Clear Counsel Law 25 Group, have agreed to accommodate Defendants’ request and stipulate to the extension of 26 discovery for an additional sixty (60) days. This Stipulation is being entered in good faith and 27 not for purposes of delay. 1 I. STATUS OF DISCOVERY 2 A. PLAINTIFF’S DISCOVERY 3 1. Plaintiff’s First Set of Interrogatories to Defendant Officer Jonathan Grant 4 dated July 7, 2025. 5 2. Plaintiff’s First Set of Requests for Admissions to Defendant Officer Jonathan 6 Grant dated July 7, 2025. 7 3. Plaintiff’s First Set of Interrogatories to Defendant Las Vegas Metropolitan 8 Police Department dated July 7, 2025. 9 4. Plaintiff’s First Set of Requests for Production of Documents to Defendant Las 10 Vegas Metropolitan Police Department dated July 7, 2025. 11 5. Plaintiff’s Initial Disclosure of Witnesses and Documents Pursuant to FRCP 12 26.1 dated July 8, 2025. 13 6. Plaintiff’s Responses to Defendants’ First Set of Requests for Production of 14 Documents dated July 17, 2025. 15 7. Plaintiff’s Answers to Defendants’ First Set of Interrogatories dated July 17, 16 2025. 17 8. Plaintiff’s Second Set of Interrogatories to Defendant Las Vegas Metropolitan 18 Police Department dated July 22, 2025. 19 9. Plaintiff’s Second Supplemental Disclosure of Witnesses and Documents 20 Pursuant to FRCP 26.1 dated October 8, 2025. 21 10. Plaintiff’s Initial Disclosure of Expert Witnesses Pursuant to FRCP 26.1 dated 22 October 8, 2025. 23 11. Plaintiff’s First Supplemental and Errata to Second Supplemental Disclosure 24 of Witnesses and Documents Pursuant to FRCP 26.1 dated October 16, 2025. 25 B. DEFENDANTS’ DISCOVERY 26 1. LVMPD Defendants’ First Set of Interrogatories to Plaintiff Shawn Armstrong 27 dated June 25, 2025. 1 2. LVMPD Defendants’ First Set of Requests for Production of Documents to 2 Plaintiff Shawn Armstrong dated June 26, 2025. 3 3. LVMPD Defendants’ Initial Disclosure of Witnesses and Documents Pursuant 4 to FRCP 26.1 dated July 1, 2025. 5 4. Defendant Officer Jonathan Grant’s Answers to Plaintiff’s First Set of 6 Interrogatories dated August 6, 2025. 7 5. Defendant Las Vegas Metropolitan Police Department’s Answers to Plaintiff's 8 First Set of Interrogatories dated August 6, 2025. 9 6. Defendant Officer Jonathan Grant’s Responses to Plaintiff’s First Set of 10 Requests for Admissions dated August 6, 2025. 11 7. LVMPD Defendants’ First Supplemental Disclosure of Witnesses and 12 Documents Pursuant to FRCP 26.1 dated August 12, 2025. 13 8. LVMPD Defendants’ Second Supplemental Disclosure of Witnesses and 14 Documents Pursuant to FRCP 26.1 dated August 13, 2025. 15 9. LVMPD Defendants’ Third Supplemental Disclosure of Witnesses and 16 Documents Pursuant to FRCP 26.1 dated August 14, 2025. 17 10. Defendant Las Vegas Metropolitan Police Department’s Answers to Plaintiff’s 18 Second Set of Interrogatories dated September 22, 2025. 19 11. Defendant Las Vegas Metropolitan Police Department’s Responses to 20 Plaintiff’s First Set of Requests for Production of Documents dated September 22, 2025. 21 12. LVMPD Defendants’ Fourth Supplemental Disclosure of Witnesses and 22 Documents Pursuant to FRCP 26.1 dated September 22, 2025. 23 13. LVMPD Defendants’ Fifth Supplemental Disclosure of Witnesses and 24 Documents Pursuant to FRCP 26.1 dated November 5, 2025. 25 C. DEPOSITIONS. 26 1. Plaintiff conducted a partial deposition of Officer Jonathan Grant on August 27 19, 2025. The remaining part of the deposition is currently noticed for November 25, 2025 at 1 2. LVMPD Defendants deposed Plaintiff Shawn Armstrong on September 5, 2 2025. 3 3. Plaintiff’s deposition of LVMPD’s 30(b)(6) designee is noticed for December 4 2, 2025. However, with the granting of this stipulation, that deposition will be moved. 5 II. DISCOVERY THAT REMAINS TO BE COMPLETED 6 The Plaintiff has almost completed his discovery and can complete discovery within 7 the current deadlines. The Defendants have completed the majority of the written discovery 8 and depositions. However, the Defendants anticipate a continued need to conduct discovery 9 and to meet and confer on outstanding discovery issues. The Parties’ primary remaining 10 discovery tasks include 1) the second part of the Plaintiff’s deposition of Defendant Officer

) the Plaintiff’s deposition of Defendant LVMPD’s 30(b)(6) witness(es), 3) the 12 potential deposition of one or more of Plaintiff’s identified expert witnesses, 4) expert rebuttal 13 reports, 5) the potential deposition of one or more of Defendants’ soon-to-be-identified 14 rebuttal expert witness(es), and 6) meet-and-confer efforts on outstanding discovery issues 15 and motion practice if needed. 16 III. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY 17 This is the first request for an extension of discovery deadlines in this matter, and the 18 first request by the Defendants. The Defendants request that the Discovery Plan and 19 Scheduling Order deadlines be extended an additional sixty (60) days so the there is more 20 flexibility with Plaintiff’s currently noticed depositions, as well as the expected deposition of 21 Defendants’ rebuttal expert, and so that Defendants may continue to conduct discovery. The 22 Parties acknowledge that, pursuant to Local Rule 26-3, a stipulation to extend a deadline set 23 forth in a discovery plan must be submitted to the Court no later than twenty-one (21) days 24 before the expiration of the subject deadline. A request made within twenty-one (21) days of 25 the subject deadline must be supported by a showing of good cause. Here, all the deadlines 26 the Defendants seek to extend are outside of the twenty-one (21) day window. Nevertheless, 27 the Defendants believe that good cause exists to extend the discovery deadline here. Plaintiff 1 makes no representations as to good cause and is simply accommodating the Defendants’ 2 request. 3 The Plaintiff identified multiple experts and disclosed expert reports on October 9, 4 2025. Defendants plan to depose one or more of those experts and disclose one or more 5 rebuttal experts on or before the rebuttal disclosure deadline. Plaintiff intends to depose any 6 identified rebuttal expert(s) disclosed by the LVMPD Defendants. 7 However, counsel for LVMPD Defendants has been preparing for and conducted a 8 two-week trial in the United States District Court, District of Nevada from October 20 through 9 November 3, 2025 in the matter of Llera, et al. v. LVMPD, et al. (Case No. 2:20-cv-01589- 10 RFB-DJA). This trial limited LVMPD Defendants’ counsel’s ability to timely review and 11 address Plaintiff’s initial expert disclosures and schedule depositions of one or more of 12 Plaintiff’s experts. 13 An extension of discovery in this matter will allow the Defendants sufficient time to 14 schedule and hold all depositions that remain to be taken, and reschedule Plaintiff’s noticed 15 depositions. Given the impending holiday season, the Defendants anticipate difficulties in 16 scheduling these depositions in the short time remaining before discovery closes. The Plaintiff 17 anticipates no scheduling issues from the Plaintiff’s side, but is willing to accommodate the 18 Defendants. The Defendants thus respectfully request an extension of time so that the 19 Defendants have sufficient time to conduct their depositions, and the Plaintiff’s noticed 20 deposition can be rescheduled to accommodate the Defendants to ensure that this matter is 21 fairly resolved on the merits. 22 The Parties met and conferred regarding the instant stipulation on 11/13/25. 23 IV. PROPOSED SCHEDULE FOR REMAINING DEADLINES 24 Item Current Deadline Proposed New Deadline 25 Amend the Pleadings / Add September 9, 2025 Past Due/Unchanged Parties 26 Initial Expert Disclosures October 9, 2025 Past Due/Unchanged 27 Rebuttal Expert Disclosures November 10, 2025 Past Due/Unchanged Discovery Cut-Off December 8, 2025 February 6, 2026 1 January 7, 2026 March 9, 2026 2\|| Pretrial Order February 6, 2026 April 7, 2026 3 4 Based on the foregoing stipulation and proposed deadlines plan, the Defendants

5 request that the Discovery Plan and Scheduling Order deadlines be extended additional sixty 6 (60) days so that the Defendants may conduct additional discovery, conduct depositions, the

7 Plaintiffs noticed depositions can be rescheduled to accommodate the Defendants’ schedule, and the Parties can litigate the case based on the merits.

9 IT IS SO STIPULATED.

10 DATED this 17th day of November, 2025 DATED this 17th day of November, 2025

Clear Counsel Law Group MARQUIS AURBACH

By: ___/s/ Stephen P. Stubbs By: __/s/ Andrew Yates 13 Stephen P. Stubbs, Esq. Craig R. Anderson, Esq. Nevada Bar No. 10449 Nevada Bar No. 6882 14 1671 W. Horizon Ridge Parkway, #200 Andrew Yates, Esq. a x Henderson, Nevada 89012 Nevada Bar No. 17016 15 Attorney for Plaintiff Shawn 10001 Park Run Drive gs 16 Armstrong Las Vegas, Nevada 89145 = 4 Attorneys for Defendants Las Vegas 617 Metropolitan Police Department and Officer Jonathan Grant 18 19 ORDER 20 The above Stipulation is hereby GRANTED. IT IS SO ORDERED. 22 23 24 UNITED STATES\MAGISTRATE JUDGE 25 DATED: 11/19/2025 26 27 28

1 CERTIFICATE OF SERVICE 2 I hereby certify that I electronically filed the foregoing STIPULATION AND 3 ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER 4 DEADLINES (DEFENDANTS’ FIRST REQUEST) with the Clerk of the Court for the 5 United States District Court by using the court’s CM/ECF system on the 17th day of 6 November, 2025. 7 I further certify that all participants in the case are registered CM/ECF users 8 and that service will be accomplished by the CM/ECF system. 9 I further certify that some of the participants in the case are not registered 10 CM/ECF users. I have mailed the foregoing document by First-Class Mail, postage prepaid, 11 or have dispatched it to a third party commercial carrier for delivery within 3 calendar days to 12 the following non-CM/ECF participants: 13 N/A

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15 /s/ Krista Busch An employee of Marquis Aurbach 16 17 18 19 20 21 22 23 24 25 26 27