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.

Ramos-Rodriguez v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

January 22, 2018

MANUEL RAMOS RODRIGUEZ, Plaintiff,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, ET AL. BECK, ALYN -LVMPD #7459; ESCARTIN, GARRETT -LVMPD # 9496; HOLLOWAY, K - LVMPD #10146; LAURENCO, ANTONIO-LVMPD#5198; RICH, BRIAN - LVMPD #14300; PORTER, H - LVMPD # 14086; THOMAS, RICHARD - LVMPD P# 9658; LOMBARCO, JOE - LVMPD - SHERIFF; MCMAHILL, KEVIN - LVMPD- UNDER I SHERIFF, REYNOLDS, LVMPD-CCDC-SERGEANT, BROWDER, TIMOTHY -IMC- HOSPITAL PHYSICIAN; DR. DURAN -CCDC NAPHCARE - PHYSICIAN; DR. ZINSER - CCDC - NAPHC ARE -PHYSICIAN, JOHN DOE - CCDC CHIEF MEDICAL ADMINISTRATOR; Defendants.

          ROBERT W. FREEMAN, Nevada Bar No. 3062, NOEL E. EIDSMORE, Nevada Bar No. 7688, LEWIS BRISBOIS BISGAARD & SMITH LLP, Attorneys for Defendants Las Vegas Metropolitan Police Officers: Alyn Beck, Garrett Escartin, Kelly Holloway, Antonio Laurenco, Brian Rich, Harrison Porter, Richard Thomas, CCDC Sergeant Jesse Reynolds

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)

         Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-captioned case ninety (90) days, up to and including Monday, April 9, 2018. In addition, the parties request that the dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days as outlined herein. In support of this Stipulation and Request, the parties state as follows:

         1. On May 23, 2017, Plaintiff filed his Second Amended Civil Rights Complaint in the United States District Court, Clark County, Nevada.

         2. On August 8, 2017, Defendants filed their Answer to Plaintiffs Second Amended Civil Rights Complaint with Federal Court.

         3. On November 13, 2017, Defendants served their Initial Disclosure of Documents and Witnesses on Plaintiff.

         4. On December 7, 2017, Defendants served written discovery on Plaintiff. Plaintiffs responses are due on January 10, 2018.

         DISCOVERY REMAINING

         1. Defendants will take the deposition of Plaintiff in January or February 2018.

         2. The parties will complete all written discovery.

         3. Defendants will collect Plaintiffs medical and billing records related to medical treatment following the incident, as well as medical records for medical treatment Plaintiff underwent prior to the subject incident.

         4. The parties will take the depositions of Plaintiff s medical providers once Defendant is able to obtain the medical records.

         5. The parties will take the depositions of any and all other witnesses garnered through discovery.

         This Request for an extension of time is not sought for any improper purpose or other purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient time to conduct discovery.

         WHY REMAINING DISCOVERY HAS ...


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.