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Taylor v. Robinson

United States District Court, D. Nevada

November 17, 2017

CAMILLE L. TAYLOR, Plaintiff,
v.
OFFICER J. ROBINSON, individually and in his official capacity; OFFICER P. AKE, individually and in his official capacity; LAS VEGAS METROPOLITAN POLICE DEPARTMENT; DOE OFFICERS I through X inclusive; ROES IX through XX, inclusive; Defendants.

          KAEMPFER CROWELL, Lyssa Anderson, Esq., Attorneys for Defendants

          E. BRENT BRYSON, PC., E. Brent Bryson, Esq., Attorney for Plaintiff

          STIPULATION TO EXTEND DISCOVERY

         IT IS HEREBY STIPULATED AND AGREED between the parties that the discovery cut-off date of February 5, 2018, be continued for a period of thirty (30) days up to and including March 7, 2018, for the purpose of allowing the parties to complete written discovery, retain and disclose expert witnesses, and take depositions of the parties.

         DISCOVERY COMPLETED TO DATE

         Plaintiff and Defendants, LAS VEGAS METROPOLITAN POLICE DEPARTMENT, OFFICER JONATHAN ROBINSON and OFFICER PAUL AKE (“LVMPD Defendants”) have exchanged their initial Rule 26(f) Disclosures.

         LVMPD Defendants served their initial written discovery requests (Interrogatories, Requests for Admissions and Requests for Production of Documents) on Plaintiff. Plaintiff's responses were due October 30, 2017. No responses have been received. LVMPD Defendants then sent a letter to Plaintiff's counsel advising them that Plaintiff's discovery were past due, and voluntarily giving Plaintiff an additional ten (10) days to respond. Plaintiff's counsel then requested an additional few days to respond, which was granted. Plaintiff's responses are now due November 22, 2017.

         DISCOVERY YET TO BE COMPLETED

         Upon receipt of the responses to written discovery from Plaintiff, LVMPD Defendants intend to serve various third-party subpoenas. Plaintiff will serve written discovery on LVMPD Defendants. The parties will conduct several depositions of the individual parties and third parties. The parties will also disclose expert and rebuttal expert witnesses.

         REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED

         LVMPD Defendants have engaged in discovery by serving their initial written discovery requests on Plaintiff. The current deadline for parties to disclose expert witnesses is December 7, 2017. Plaintiff's responses to the initial written discovery are due November 22, 2017, less than three (3) weeks before the expert disclosure deadline. LVMPD Defendants are not able to obtain an expert report without documents from third-parties which must be subpoenaed. The subpoenas cannot be issued until LVMPD Defendants receive an executed medical authorization from Plaintiff, which was requested in LVMPD Defendants' initial written discovery requests to Plaintiff. As such, the parties require additional time to continue discovery and provide the information to experts.

         PROPOSED EXTENDED DEADLINES

         Accordingly, it is hereby stipulated and respectfully requested that this Court enter an order as follows:

         (A) Discovery Deadline.

         That the current discovery cut-off date of February 5, 2018, be extended for a period of 8 thirty (30) days, ...


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