McLaine v. Clark County, Nevada et al

Filing 104

ORDER Granting 103 Stipulation About Discovery Procedure. Plaintiff's counsel shall file a status report on or before 11/18/16 indicating which depositions identified in the stipulation have been completed. Signed by Magistrate Judge George Foley, Jr. on 10/28/16. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:14-cv-00288-JAD-GWF Document 103 Filed 10/27/16 Page 1 of 4

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Paul S. Padda, Esq. (NV Bar #10417)
Email: [e-mail]
PAUL PADDA LAW, PLLC
4240 West Flamingo Road, Suite 220
Las Vegas, Nevada 89 1 03
Tele: [phone]
Fax:[phone]

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Attorney for the Plaintiff

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UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF NEVADA
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9 J SHENDONNA SOPHIA McLAINE,
Plaintiff,

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v.

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CLARK COUNTY, NEVADA; et. aL,
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Case No. 2:14-cv-0288-JAD-GWF

Defendants.
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)
STIPULATION ABOUT DISCOVERY PROCEDURE
Pursuant to Federal Rule of Civil Procedure 29 the parties respectfully request that the

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Court approve this stipulation governing discovery procedure. At the outset it should be

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emphasized that this is not a stipulation to extend discovery, which closes on October 3 1, 201 6.

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Rather, this is simply a stipulation to permit the parties to complete various depositions that were

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timely noticed prior to the close of discovery but due to scheduling conflicts must now be

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completed after the close of discovery. In submitting this stipulation for approval to the Court,

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the parties intend to complete the depositions of the following individuals within approximately

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the next two weeks:

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"PMK" of Las Vegas Metropolitan Police Department;
"PMK" of the Clark County District Attorney's Office;
"PMK" of Clark County, Nevada;

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Christopher Lalli, Esq.

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Frank Coumou, Esq.

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Peter Thunell, Esq.
Michelle Anthony, Esq.
Aaron Nance, Esq.
Phillip J. Kohn, Esq.
Benjamin Saxe, Esq.
Tom Roberts
Officer Scott Friedman
Officer Richard Zaccara

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Additionally, Plaintiffs counsel intends to depose Alexandra Chrysanthis, Esq., Craig Hendricks,

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Esq., Michael Radovcic, Esq. and Brett Keller, Esq.. All four individuals were formerly

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employed by the Clark County District Attorney's Office.

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Although this may appear to be a large number of depositions, the majority of them are

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not anticipated to last more than an hour and several can be taken on the same day. Further, the

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parties anticipate the majority, if not all, of the above-identified individuals will be deposed

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within the next two weeks. This stipulation is being filed merely for the purpose of

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accommodating the busy schedules of the various witnesses, many of whom are attorneys, who

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would otherwise have to appear on the currently scheduled dates prior to the close of discovery.

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Plaintiffs counsel has represented that no other depositions will be noticed apart from the ones

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involving the individuals identified in this stipulation. Neither side will engage in any written

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discovery. Thus, as indicated above, this is not an extension of discovery per se but instead

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merely a request seeking approval to complete certain depositions outside the close of discovery.

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Case 2:14-cv-00288-JAD-GWF Document 103 Filed 10/27/16 Page 3 of 4

The parties respectfully request that the Court approve this stipulation which is not filed

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for the purpose of delay but rather merely to accommodate the busy schedules of various

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witnesses and for the purpose of completing depositions that were otherwise timely noticed.

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Respectfully submitted,

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/s/

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Lucinda L. Coumou, Esq.
Chief Deputy District Attorney, Civil Division
Clark County District Attorney's Office

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L. CcnMM-ow

/s/ FcuaL S. PcuLdxxs
Paul S. Padda, Esq.
Paul Padda Law
Attorney for Plaintiff

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Attorney for Defendants Clark County, Nevada
and the Clark County District Attorney's Office

Dated: October 27, 2016

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Dated: October 27, 2016

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/s/ Poh^rtVJ. Fre-evvu^vv, Jr.
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Robert W. Freeman, Jr., Esq.
Lewis Brisbois Bisgaard & Smith
Attorney for Las Vegas Metropolitan Police Department
and Officers R. Zaccara and S. Friedman

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Dated: October 27, 2016
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IT IS SO ORDERED:

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The Court hereby approves the parties' stipulation filed
pursuant to Federal Rule of Civil Procedure 29. The

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parties represent that they are not seeking an extension
of the discovery period but instead seek merely to

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complete depositions that were timely noticed prior to
the close of discovery. Plaintiffs counsel shall file a

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status report on or before November 18, 2016 indicating
which depositions identified in the stipulation have been

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completed. No discovery beyond completion of the
depositions of the individual witnesses identified in the
stipulation shall be permitted.

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UNITED STATES MAGISTRATE JUDGE

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Dated: October

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28th

, 2016