Wildeveld-Coneh v. Las Vegas Metropolitan Police Department et al

Filing 21

ORDER Granting 18 Stipulation to Extend Discovery and Other Deadlines (Discovery due by 9/9/2011, Motions due by 10/7/2011, Proposed Joint Pretrial Order due by 11/4/2011.) Signed by Magistrate Judge Peggy A. Leen on 6/30/2011. (Copies have been distributed pursuant to the NEF - DXS)

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CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
JOHN C. FUNK, ESQ.
Nevada Bar No. 9255
POTTER LAW OFFICES
1125 Shadow Lane
Las Vegas, Nevada 89102
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
•••••

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KRISTINA WILDEVELD-CONEH,
Case No.: 2:10-cv-00983-RLH-PAL

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Plaintiff,
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v.
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LAS VEGAS METROPOLITAN POLICE
DEPARTMENT, a Political Subdivision
of the STATE OF NEVADA; Police Officer
RICHARD DEAN GOSLAR, individually
and as a police officer employed by the
LAS VEGAS METROPOLITAN POLICE
DEPARTMENT; POLICE OFFICERS
JOHN DOES I-XX; and JOHN DOES
I-XX, inclusive,

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Defendants.
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STIPULATION AND ORDER TO EXTEND DISCOVERY
AND OTHER DEADLINES
(Third Request)

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Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record,

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hereby stipulate and request that this Court extend the discovery deadlines, including the current

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discovery cut-off of Monday, July 11, 2011, in the above-captioned case for and additional sixty (60)

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days, up to and including Friday, September 9, 2011. In addition, the parties request that the

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dispositive motions, and pretrial order deadlines be extended as outlined herein. In support of this

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Stipulation and Request, the parties state as follows:

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DISCOVERY COMPLETED TO DATE

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October 11, 2010, Las Vegas Metropolitan Police Department’s Request for Admissions

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to Plaintiff;
October 11, 2010, Las Vegas Metropolitan Police Department’s Interrogatories to

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Plaintiff;
October 11, 2010, Las Vegas Metropolitan Police Department’s Request for Production of

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Documents to Plaintiff;

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October 11, 2010, Defendant Officer Richard Dean Goslar’s Interrogatories to Plaintiff;

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October 11, 2010 Defendant Officer Richard Dean Goslar’s Request for Production of

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Documents to Plaintiff;
November 15, 2010, Defendants’ Fed. R. Civ. P. 26-1 Production and Witness Disclosure;

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December 1, 2010, Plaintiff’s Responses to Defendant Las Vegas Metropolitan Police

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Department’s First Set of Request for Admissions;

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December 7, 2010, Plaintiff’s FRCP 26.1 Initial Disclosure of Witnesses and Documents;

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January 3, 2011, Plaintiff’s Response to Las Vegas Metropolitan Police Department’s

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Interrogatories;
January 3, 2011, Plaintiff’s Response to Las Vegas Metropolitan Police Department’s

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Request for Production of Documents;
January 3, 2011, Plaintiff’s Response to Defendant Officer Richard Dean Goslar’s

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Interrogatories;
January 3, 2011, Plaintiff’s Response to Defendant Officer Richard Dean Goslar’s Request

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for Production of Documents;
January 4, 2011, Plaintiff’s First Supplement to FRCP 26.1 Initial Disclosure of Witnesses

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and Documents;

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January 6, 2011, Defendants’ First Supplemental Disclosures;

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January 19, 2011, Defendants noticed the deposition of Plaintiff;

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January 28, 2011, Defendants amended the notice of deposition of Plaintiff;

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February 2, 2011, Plaintiff noticed the deposition of witness, Larry Threadgill;

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February 2, 2011, Plaintiff noticed the deposition of Defendant Officer Richard Dean

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Goslar;
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March 9, 2011, deposition of Plaintiff Kristina Wildeveld-Coneh, volume 1;

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March 13, 2011, Defendant noticed the independent medical examination of Plaintiff;

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March 14, 2011, Defendant noticed the continued deposition of Plaintiff;

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March 15, 2011, Defendant vacated the notice of continued deposition of Plaintiff;

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March 21, 2011, deposition of Defendant Officer Richard Dean Goslar;

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March 23, 2011, deposition of witness Larry Threadgill;

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April 19, 2011, Defendants’ Second Supplemental Disclosure;

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May 2, 2011, independent medical examination of Plaintiff;

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May 6, 2011, Defendant amended the notice of continued deposition of Plaintiff;

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May 12, 2011, Defendants’ Designation of Expert Witnesses;

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May 12, 2011, Plaintiff’s Designation of Expert Witnesses;

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May 24, 2011, Defendants’ Third Supplemental Disclosure;

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June 7, 2011, Defendants noticed the deposition of Stephanie Youngblood, D.C.

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June 7, 2011, Defendants noticed the deposition of Terry Pfau, M.D.

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June 16, 2011, Defendants vacated the deposition of Terry Pfau, M.D.

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DISCOVERY REMAINING
Plaintiffs and Defendants need additional time to take expert depositions, witness/PMK

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depositions, conduct discovery regarding the written discovery responses, and propound other

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written discovery.

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WHY SUCH REMAINING DISCOVERY HAS NOT BEEN COMPLETED
The parties have been consistently keeping up on the deadlines as extended in Court

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Docket #17. However, due to scheduling conflicts and unexpected circumstances, the parties

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request that the discovery deadlines be extended to allow sufficient time for depositions to be set

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and to propound any additional written discovery.

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REASONS FOR REQUEST
Due to the reasons set forth above, the parties have stipulated to the following proposed
schedule for the remaining discovery by sixty (60) days:

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Scheduled Event

Proposed Deadline

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Extension of Discovery Deadline

Friday, August 19,2011

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Discovery Cut-off

Friday, September 9, 2011

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Dispositive Motions

Friday, October 7, 2011

Joint Pretrial Order

Friday, November 4, 2011

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RESPECTFULLY SUBMITTED this 17th day of June, 2011.
POTTER LAW OFFICES

OLSON, CANNON, GROMLEY
& DESRUISSEAUX

By /s/ Cal J. Potter, III, Esq.
CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
JOHN C. FUNK, ESQ.
Nevada Bar No. 9255
1125 Shadow Lane
Las Vegas, Nevada 89102
Attorneys for Plaintiff

By /s/ Thomas D. Dillard, Jr., Esq.
THOMAS D. DILLARD, JR., ESQ.
Nevada Bar No. 6270
9950 West Cheyenne Avenue
Las Vegas, Nevada 89129
Attorneys for Defendants

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ORDER
IT IS SO ORDERED.
Dated this

day of

, 2011.

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_________________________________________
U.S. DISTRICT COURT MAGISTRATE JUDGE

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