Guevara v. Las Vegas Metropolitan Police Department

Filing 21

ORDER Granting 20 Stipulation to Extend Discovery Deadlines 12 . (First Request) New Deadlines: Discovery cut-off: 10/19/2015; Amending Pleadings or Adding Parties: 7/21/2015; Expert Disclosures: 8/20/2015; Rebuttal Expert Disclosures: 9/18/2015; Dispositive Motions: 11/18/2015; Interim Status Report: 8/20/2015; and Proposed Joint Pretrial Order: 12/17/2015. Signed by Magistrate Judge Peggy A. Leen on 6/29/2015. (Copies have been distributed pursuant to the NEF - PS) (Main Document 21 replaced on 6/29/2015) (PS).

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Marquis Aurbach Coffing
Nick D. Crosby, Esq.
Nevada Bar No. 8996
10001 Park Run Drive
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for LVMPD

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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WILMER GUEVARA,
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Case No.:
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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

2:15-cv-00008-APG-PAL

Plaintiff,
vs.

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LAS VEGAS METROPOLITAN
POLICE DEPARTMENT,

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Defendant.

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STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
(FIRST REQUEST)

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Pursuant to Local Rule 26-4, Defendant, Las Vegas Metropolitan Police Department

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(“Department”), by and through its counsel of record, Nick D. Crosby, Esq. of the law firm of

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Marquis Aurbach Coffing, and Plaintiff, Wilmer Guevara (“Plaintiff”), by and through his

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counsel of record Adam Levine, Esq. of the Law Offices of Daniel Marks, hereby agree and

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stipulate to extend discovery 90 days.

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I.

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LOCAL RULE 26-4 REQUIREMENTS
A.

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DISCOVERY COMPLETED.
1.

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The Depar tment’s Discover y.

To date, Defendant has not propounded written discovery upon Plaintiff but anticipates

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the same will be served within 7 days.

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2.

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Plaintiff’s Discover y.

To date, Plaintiff has served Requests for Production of Documents on Defendant, which
have been responded to by Defendant.

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B.

DISCOVERY THAT REMAINS TO BE COMPLETED.

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1.

Written discovery of the parties;

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2.

Depositions of witnesses; and

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3.

Expert discovery.

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C.

REASONS WHY DISCOVERY CANNOT BE COMPLETED WITHIN
THE TIME LIMITS SET BY THE DISCOVERY PLAN.

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Both counsel for Plaintiff and Defendant have been heavily involved in labor arbitrations
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and prohibited labor practices hearings before the Employee Management Relations Board
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(“Board”).

Further, the attorney handling this matter for Defendant recently left the firm,

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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

requiring the undersigned defense counsel to take over the case.
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D.

PROPOSED SCHEDULE FOR COMPLETING DISCOVERY.

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1.

Discover y Cutoff Date.

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In accordance with Local Rule 26-1(e)(1), the discovery cutoff shall be extended by 90
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days from July 21, 2015 to October 19, 2015.
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2.

Amending the Pleadings and Adding Par ties.

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In accordance with Local Rule 26-1(e)(2), the last day to file a motion to amend the
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pleadings or to add parties shall be extended by 90 days from April 22, 2015 to July 21, 2015.
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3.

Exper ts.

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In accordance with Local Rule 26-1(e)(3), the last day for disclosures as required by
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FRCP 26(a)(2)(c) concerning experts shall be extended by 90 days from May 22, 2015 to
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August 20, 2015. The last day for disclosures concerning rebuttal experts shall be extended by
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90 days from June 22, 2015 to September 18, 2015.
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4.

Dispositive Motions.

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In accordance with Local Rule 26-1(e)(4), the last day for filing dispositive motions

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including, but not limited to motions for summary judgment, shall be extended by 90 days from

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August 20, 2015 to November 18, 2015.

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5.

Inter im Status Repor t.

In accordance with Local Rule 26-3, the last day to file an Interim Status Report shall be
90 days from May 22, 2015 to August 20, 2015.

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6.

Pr etr ial Or der .

In accordance with Local Rule 26-1(e)(5), the last day to file a Joint Pretrial Order, including

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any disclosures pursuant to FRCP 26(a)(3), shall be extended by 90 days from September 18, 2015 to

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December 17, 2015. In the event dispositive motions are filed, the date for filing the Joint Pretrial

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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

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Order shall be suspended until thirty (30) days after decision on the dispositive motions or upon

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further Order by the Court extending the time period in which to file the Joint Pretrial Order.

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7.

Extension of Scheduled Deadlines.

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In accordance with Local Rule 26-4, all motions or stipulations to extend a deadline set

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forth in the discovery plan shall be received by the Court no later than twenty-one (21) days

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before the expiration of the subject deadline.

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Dated this

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LAW OFFICE OF DANIEL MARKS

MARQUIS AURBACH COFFING

By: /s/ Adam Levine
Adam Levine, Esq.
Nevada Bar No. 4673
610 South Ninth Street
Las Vegas, Nevada 89101
Attorney for Plaintiff

By: /s/ Nick D. Crosby
Nick D. Crosby, Esq.
Nevada Bar No. 8996
10001 Park Run Drive
Las Vegas, Nevada 89145
Attorney for LVMPD

25th

day of June, 2015.

Dated this

25th day of June, 2015.

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ORDER
IT IS SO ORDERED this 29th day of June, 2015.

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UNITED STATES MAGISTRATE JUDGE
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