Looper v. Las Vegas Metropolitan Police Department et al

Filing 22

ORDER granting 21 Stipulation to Extend Discovery Deadlines. Discovery due by 11/5/2024. Motions due by 12/3/2024. Proposed Joint Pretrial Order due by 1/2/2025. Signed by Magistrate Judge Elayna J. Youchah on 7/2/2024. (Copies have been distributed pursuant to the NEF - CT)

Download PDF
1 Marquis Aurbach Craig R. Anderson, Esq. 2 Nevada Bar No. 6882 10001 Park Run Drive 3 Las Vegas, Nevada 89145 Telephone: (702) 382-0711 4 Facsimile: (702) 382-5816 canderson@maclaw.com 5 Attorneys for Defendants LVMPD, Ofc. Obsenares and Ofc. McMahill 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 JACEY LOOPER, individually, 9 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 10 Case Number: 2:23-cv-01436-JAD-EJY Plaintiff, vs. 11 LAS VEGAS METROPOLITAN POLICE DEPARTMENT; GLENN OBSENARES; 12 BRAYDEN MCMAHILL and DOES 1-10, inclusive, 13 Defendants. 14 15 STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST) Plaintiff Jacey Looper (“Plaintiff”), by and through her attorneys of record, 16 Christiansen Trial Lawyers and Peter Goldstein Law Corp. and Defendants Las Vegas 17 Metropolitan Police Department (“LVMPD”), Ofc. Obsenares and Ofc. McMahill 18 (“Defendants”), by and through their attorneys of record, Marquis Aurbach, hereby file their 19 Stipulation and Order to Extend Discovery Deadlines (Second Request) by ninety (90) days 20 pursuant to LR II 26-4. The present discovery cutoff date is August 5, 2024. 21 I. DISCOVERY COMPLETED 22 1. On December 13, 2023 this Court entered the original discovery plan. (ECF 23 No. 17) 24 2. Plaintiff served her initial FRCP 26(a)(1) disclosure. 25 3. Defendants served their initial FRCP 26(a)(1) disclosure. 26 4. The parties have both severed and responded to written discovery. 27 5. On January 25, 2024, the Parties extended discovery 90-days for the first 28 time. (ECF No. 20) Page 1 of 4 MAC:14687-472 5527971_1 7/2/2024 1:24 PM 1 6. Both parties have served several supplements to their initial Rule 26 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 2 disclosure statements. 3 7. Both parties have served initial expert disclosures. 4 8. The Defendants have taken the deposition of Plaintiff. 5 9. Plaintiff deposed both individual defendants. 6 10. Both parties have served numerous Custodian of Records depositions. 7 II. DISCOVERY TO BE COMPLETED 8 1. The Parties need to serve rebuttal expert reports. 9 2. Plaintiff needs to depose Defendants’ medical and police practice experts. 10 3. Defendants need to depose Plaintiff’s medical and police practices expert. 11 4. Defendants will need to take the deposition of Plaintiff’s experts. 12 5. The Plaintiff has noticed a Rule 30(b)(6) for LVMPD. 13 III. REASONS WHY THE DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE TIME LIMITS SET BY THE COURT 14 The parties agree, pursuant to Local Rule 6-1, that good cause exists for the 15 requested extension. The primary reason for this request is for the Parties to complete expert 16 discovery. Although both Parties have served initial expert discovery, it has been difficult 17 setting expert depositions due to scheduling. In addition, the Parties are attempting to find an 18 agreeable date to conduct the Rule 30(b)(6) deposition for LVMPD. 19 Counsel for Plaintiff and Defendants just finished a ten-day jury trial (June 17, 2024 20 through June 26, 2024) in Estate of Childress, et al. v. LVMPD, et al., Case No. 2:16-cv21 03039-APG-NJK. Defense counsel is starting a two-week jury trial on July 29, 2024 in the 22 United States District Court entitled Estate of Jose Gomez, et al. v. LVMPD, et al., Case No. 23 2:20-cv-01589-RFB-BNW. Due to these conflicts, other pending deadlines, and the summer 24 schedules of the expert witnesses, the Parties have been unable to find agreeable dates for 25 expert depositions until late August/September. Therefore, the Parties agree that a 90-day 26 extension will allow the Parties to complete the remaining depositions, obtain the 27 transcripts, and file dispositive motions. 28 Page 2 of 4 MAC:14687-472 5527971_1 7/2/2024 1:24 PM 1 IV. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY: 2 3 Close of Discovery EXISTING DEADLINES PROPOSED DEADLINES August 5, 2024 November 5, 2024 4 5 6 7 8 9 10 Final Date to Amend Pleadings/Add Parties Passed Initial Expert Disclosures Deadlines Passed Rebuttal Expert Disclosure Deadline July 3, 2024 August 3, 2024 Final Date for Dispositive Motions September 3, 2024 December 3, 2024 Pretrial Order October 1, 2024 January 2, 2025 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 12 13 14 IT IS SO STIPULATED this 2nd day of July, 2024. 15 MARQUIS AURBACH CHRISTIANSEN TRIAL LAWYERS 16 17 By: s/Craig R. Anderson Craig R. Anderson, Esq. 18 Nevada Bar No. 6882 10001 Park Run Drive 19 Las Vegas, Nevada 89145 Attorney for Defendants 20 By: s/R. Todd Terry Peter S. Christiansen, Esq. Nevada Bar No. 5254 R. Todd Terry, Esq. Nevada Bar No. 6519 710 South 7th Street, Suite B Las Vegas, Nevada 89101 Attorneys for Plaintiff 21 PETER GOLDSTEIN LAW CORP 22 23 24 25 26 IT IS SO ORDERED. By: ________________________________ U.S. MAGISTRATE JUDGE s/Peter Goldstein Peter Goldstein, Esq. Nevada Bar No. 6992 10161 Park Run Drive, Suite 150 Las Vegas, Nevada 89145 Attorneys for Plaintiffs Date: July 2, 2024 27 28 Page 3 of 4 MAC:14687-472 5527971_1 7/2/2024 1:24 PM

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?