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Harlow v. Nevada Properties 1 LLC

United States District Court, D. Nevada

February 21, 2018

CHRIS HARLOW and DEMIA HARLOW, Plaintiffs,
v.
NEVADA PROPERTY 1 LLC d/b/a THE COSMOPOLITAN OF LAS VEGAS; LAS VEGAS METROPOLITAN POLICE DEPARTMENT; GRAY CLARKE; DOES 1-30, inclusive; and, ROE CORPORATIONS 1-10, inclusive. Defendants.

          LYSSA S. ANDERSON, RYAN W. DANIELS, KAEMPFER CROWELL Attorneys for Defendant LAS VEGAS METROPOLITAN POLICE DEPARTMENT

          Lucas A. Grower, Esq. Attorneys for Plaintiffs

          Jason C. Foulger, Esq. Attorneys for Nevada Property 1, LLC d/b/a The Cosmopolitan of Las Vegas

          STIPULATION TO EXTEND DISCOVERY

         IT IS HEREBY STIPULATED AND AGREED between the parties that the discovery cutoff date of May 16, 2018, be continued for a period of sixty (60) days up to and including July 16, 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, (“LVMPD”) and NEVADA PROPERTY 1 LLC d/b/a THE COSMOPOLITAN OF LAS VEGAS (“Cosmopolitan”) have exchanged their initial Rule 26(f) Disclosures.

         LVMPD served its initial written discovery requests (Interrogatories, Requests for Admissions and Requests for Production of Documents) on Plaintiffs. Plaintiffs have responded to the Interrogatories and Requests for Production of Documents; responses to the Requests for Admissions are due February 26, 2018. Similarly, Cosmopolitan served its initial written discovery requests on Plaintiffs; which responses are currently outstanding.

         LVMPD has served several third-party subpoenas and has received responses to some of the subpoenas. There are still some outstanding responses due.

         DISCOVERY YET TO BE COMPLETED

         LVMPD is currently preparing a disclosure with materials it has received to date from responses to subpoenas. LVMPD will make an additional supplement once additional responses are received. Plaintiffs will respond to Cosmopolitan's outstanding written discovery requests. 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

         The parties have been actively engaged in discovery in this matter. However, LVMPD is not able to obtain an expert report without documents from third-parties which are slowly being received in response to the subpoenas. The materials exchanged by the parties and received in response to subpoenas to date are voluminous. The current deadline to disclose expert reports is March 19, 2018. Due to the amount of materials the experts must review and because there is some discovery still outstanding, the experts will need additional time to review all materials before preparing their reports. 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 ...


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