1 LYSSA S. ANDERSON Nevada Bar No. 5781 2 KRISTOPHER J. KALKOWSKI Nevada Bar No. 14892 3 TRAVIS C. STUDDARD Nevada Bar No. 16454 4 KAEMPFER CROWELL 1980 Festival Plaza Drive, Suite 650 5 Las Vegas, Nevada 89135 Telephone: (702) 792-7000 6 Fax: (702) 796-7181 [email protected] 7 [email protected] [email protected] 8 Attorneys for Defendant 9 Las Vegas Metropolitan Police Department 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 REGINA MCINTYRE, individually, and Case No.: 2:24:cv-01953-APG-EJY REGINA MCINTYRE, acting on behalf of the 13 Estate of James Chatien, STIPULATION TO EXTEND 14 Plaintiffs, DISCOVERY vs. (Third Request) 15 LAS VEGAS METROPOLITAN POLICE 16 DEPARTMENT, a political subdivision of the State of Nevada; STATE OF NEVADA; 17 CLARK COUNTY SHERIFF’S OFFICE; CLARK COUNTY DETENTION CENTER; 18 CITY OF LAS VEGAS; and DOES 1 through 10, Corporate DOES 1 through 10, 19 Defendants. 20 21 IT IS HEREBY STIPULATED AND AGREED between the parties that the discovery 22 cut-off date of January 26, 2026, be continued for a period of sixty days up to and including 23 Friday March 27, 2026, for the purpose of the parties being able to determine the scope of 24 discovery in this matter following a ruling on LVMPD’s pending Motion to Dismiss, for Plaintiff 1 to respond to written discovery, for the parties to take depositions and to allow disclosure of 2 expert and rebuttal expert reports. 3 I. DISCOVERY COMPLETED TO DATE 4 LVMPD provided its Initial Rule 26 Disclosures to Plaintiff which included nearly three-

5 thousand (3000) pages. Plaintiff has not yet provided her Rule 26 Disclosures. LVMPD served 6 Requests for Production of Documents and Interrogatories on Plaintiff which responses are due 7 December 13, 2025. 8 II. DISCOVERY YET TO BE COMPLETED 9 LVMPD will be providing supplemental Rule 26 Disclosures to Plaintiff. LVMPD is 10 currently reviewing additional materials for the supplemental disclosure. Plaintiff will make her 11 Initial Rule 26 Disclosures and likewise, serve written discovery on LVMPD. Plaintiff will 12 respond to the written discovery served on December 13, 2025, and additional written discovery 13 may be necessary. Additional information and documents will be provided to experts to review. 14 Experts will finish preparing draft reports and timely expert disclosures will be made. The

15 parties will coordinate and conduct the deposition of Plaintiff and Rule 30(b)(6) witnesses. Any 16 necessary third-party subpoenas will be made. In the event the pending Motion to Dismiss is 17 granted but giving Plaintiff leave to amend her Complaint, the parties will be able to efficiently 18 proceed with conducting further discovery in this matter. 19 III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED 20 A standard of “good cause” governs this request because the to-be-extend deadlines have 21 not yet expired. D. Nev. Local Rule 26-3. Good cause “primarily considers the diligence” of the 22 parties seeking the extension. Johnson v. Mammoth Recreations, Inc.,

(9th 23 Cir. 1992) (explaining that “[t]he district court may modify the pretrial schedule if it cannot

24 reasonably be met despite the diligence of the party seeking the extension.”) (internal quotations 1 omitted). “Motions for extension must include a statement specifying the discovery completed, a 2 description of discovery remaining, the reasons why the deadline was not satisfied, and a 3 proposed schedule for completing remaining discovery.” Hampton v. Nevada, No. 2:20-cv- 4 00578-APG-DJA,

, at *2 (D. Nev. July 29, 2021).

5 On October 3, 2025, LVMPD filed a Motion to Dismiss in response to the First Amended 6 Complaint which seeks dismissal of claims on the basis that certain claims are improper and 7 redundant. The Motion is fully briefed and pending. The Court’s resolution of this Motion will 8 impact the scope of discovery and, thus, supports good cause to extend discovery at this time 9 while waiting for a decision. 10 Further, the expansive claims in this case require additional time for discovery. The 11 claims surround the death of a former CCDC inmate by another CCDC inmate. The incident 12 was investigated on various fronts by LVMPD, and any non-privileged materials will be 13 disclosed. It has taken and will continue to take considerable time and resources to gather and 14 assemble materials and information relevant to the claims and defenses in this matter—as it has

15 to date with LVMPD Defendants’ compilation and prior disclosure of roughly 3,000 pages. 16 The parties submit that these reasons satisfy the applicable good cause standard imposed 17 by Local Rule 26-3 for an extension of the current discovery deadlines. 18 IV. PROPOSED EXTENDED DEADLINES 19 The parties respectfully request this Court enter an order as follows: 20 Deadline Current Date Proposed New Date 21 Discovery Cut Off January 26, 2026 March 27, 2026 22 Disclosure of Experts December 1, 2026 January 26, 2026 23 Disclosure of Rebuttal Experts December 30, 2025 February 25, 2026

24 1 Deadline Current Date Proposed New Date 2 Dispositive Motion Deadline: February 26, 2026 April 27, 2026 3 Pre-Trial Order March 27, 2026 May 27, 2026 4

5 (A) Motions in Limine/Daubert Motions. 6 Under LR 16-3(b), any motions in limine, including Daubert motions, shall be filed and 7 served 30 days prior to the commencement of Trial. Oppositions shall be filed and served 14 8 days thereafter. Reply briefs will be allowed only with leave of the Court. 9 (B) Pretrial Order. 10 Pursuant to LR 26(1)(e)(5), the Joint Pretrial Order shall be filed with this Court no later 11 than thirty days after the date set for filing dispositive motions, unless dispositive motions are 12 filed, in which case the date for filing the Joint Pretrial Order shall be suspended until 30 days 13 after the decision on the dispositive motions or further order of this Court. The disclosures 14 required by FRCP 26(a)(3) and any objections shall be included in the final pretrial order.

15 (C) Extensions or Modification of the Discovery Plan and Scheduling Order. 16 In accordance with LR 26-3, applications to extend any date set by the discovery plan, 17 scheduling order, or other order must, in addition to satisfying the requirements of LR 6-1, be 18 supported by a showing of good cause for the extension. All motions or stipulations to extend a 19 deadline set forth in a discovery plan shall be received by the Court not later than 21 days before 20 the expiration of the subject deadline. A request made after the expiration of the subject deadline 21 shall not be granted unless the movant demonstrates that the failure to set was the result of 22 excusable neglect. Any motion or stipulation to extend a deadline or to reopen discovery shall 23 include:

24 / / / 1 (a) A statement specifying the discovery completed; 2 (b) A specific description of the discovery that remains to be completed; 3 (c) The reasons why the deadline was not satisfied or the remaining discovery was 4 not completed within the time limits set by the discovery plan; and

5 (d) A proposed scheduled for completing all discovery. 6 The parties submit that good cause exists for an extension of the discovery deadlines for 7 the reasons stated above. The parties intend to conduct discovery in an expeditious manner 8 following a ruling on the pending Motion. This delay will not impede this matter and, in fact, 9 will allow the Court time to rule on the pending Motion to Dismiss and the parties to continue to 10 conduct discovery in an effective and efficient manner. No Trial has been set and dispositive 11 motions have not been filed. 12 IT IS SO STIPULATED this 25th day of November, 2025. 13 KAEMPFER CROWELL 14 By: /s/ Lyssa S. Anderson By: /s/ Michael Mee LYSSA S. ANDERSON MICHAEL MEE 15 Nevada Bar No. 5781 Nevada Bar No. 13726 KRISTOPHER J. KALKOWSKI 400 S. 4th Street 16 Nevada Bar No. 14892 Las Vegas NV 89101 TRAVIS C. STUDDARD Attorney for Plaintiff 17 Nevada Bar No. 16454 1980 Festival Plaza Drive Suite 650 18 Las Vegas, Nevada 89135 Attorneys for LVMPD 19 Defendants 20 ORDER 21 IT IS SO ORDERED. 22 Dated this 25th day of November, 2025. 23 24 UNITED STATES MAGISTRATE JUDGE