United States District Court, D. Nevada
CHRISTOPHER GARDNER, Individually and as heir and as Special Administrator for THE ESTATE OF ELLEN FINNIE GALLUCCI, Plaintiffs,
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
OFFICES OF KEVIN R. HANSEN KEVIN R. HANSEN, ESQ. AMY M.
WILSON, ESQ. ATTORNEYS FOR PLAINTIFFS
STIPULATION TO EXTEND DISCOVERY
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
COMPLETED TO DATE
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.
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.
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.
YET TO BE COMPLETED
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.
WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED
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
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
it is hereby stipulated and respectfully requested that this