Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Gardener v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

January 16, 2018

CHRISTOPHER GARDNER, Individually and as heir and as Special Administrator for THE ESTATE OF ELLEN FINNIE GALLUCCI, Plaintiffs,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, Political Subdivision of the State of Nevada; SHERIFF JOSEPH LOMBARDO; DOE OFFICERS I-X, and DOES XI through XX; and ROE BUSINESS ENTITIES XXI through XXX, inclusive. Defendants.

          KAEMPFER CROWELL LYSSA S. ANDERSON, ESQ. RYAN DANIELS, ESQ. ATTORNEYS FOR DEFENDANTS

          LAW OFFICES OF KEVIN R. HANSEN KEVIN R. HANSEN, ESQ. AMY M. WILSON, ESQ. ATTORNEYS FOR PLAINTIFFS

          STIPULATION TO EXTEND DISCOVERY

         IT IS HEREBY STIPULATED AND AGREED between the parties that the discovery cut-off date of March 14, 2018, be continued for a period of ninety (90) days, up to and including June 12, 2018, for the purpose of allowing the parties to finish conducting written discovery, serve third-party subpoenas, take several depositions of third parties and disclose expert witnesses.

         DISCOVERY COMPLETED TO DATE

         Plaintiff, CHRISTOPHER GARDNER, Individually and as heir and as Special Administrator for THE ESTATE OF ELLEN FINNIE GALLUCCI (“Plaintiff”), has produced his first supplement to Rule 26 disclosures to LAS VEGAS METROPOLITAN POLICE DEPARTMENT and SHERIFF JOSEPH LOMBARDO (“Defendants”). Plaintiff has produced written discovery requests (Interrogatories and Requests for Production of Documents) on Defendants. Defendants have answered said requests. Plaintiff has also taken the depositions of several LVMPD officers.

         Defendants have produced their first, second, third and fourth supplements to their Rule 26 disclosures. Defendants have also served Plaintiff with their initial written discovery requests and a second set (Interrogatories and Requests for Production of Documents). Plaintiff has responded to Defendant's both sets.

         The depositions of five (5) individual LVMPD Officers have been taken. Additional depositions of more LVMPD Officers were scheduled; however, those had to be vacated due to conflicts with the schedules of Counsels and the Officers.

         DISCOVERY YET TO BE COMPLETED

         Plaintiffs will take depositions of several more of the officers involved, which previously had to be cancelled. Both parties will schedule depositions of third-party witnesses. The parties will disclose experts and rebuttal expert reports.

         REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED

         With a case of this size and complexity, the parties request to extend discovery deadlines to be sure the expert witnesses are disclosed and discovery is completed in a timely manner. Throughout the discovery already completed, additional facts, parties, and witnesses have been discovered. Both parties wish to be thorough in their investigations of the extensive documentation on this incident and be sure all the correct information is disclosed. Moreover, there have been delays in discovery concerning deposition transcripts and scheduling depositions. Those delays are more particularly set out herein.

         Plaintiff filed a Second Amended Complaint naming the officers involved in the incident. Defendants have filed a Motion to Dismiss the Second Amended Complaint. Plaintiff has filed his Opposition, and the parties are waiting to hear the judge's decision.

         PROPOSED EXTENDED DEADLINES

         Accordingly, it is hereby stipulated and respectfully requested that this ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.