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Estate of Farmer v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

May 7, 2018

ESTATE OF TASHI S. FARMER a/k/a TASHII FARMER a/k/a TASHII BROWN, by and through its Special Administrator, Lorin Michelle Taylor; TAMARA BAYLEE KUUMEALI'MAKAMAE FARMER DUARTE, a minor, individually and as Successor-in-Interest, by and through her legal guardian, Stevandra Lk Kuanoni; ELIAS BAY KAIMIPONO DUARTE, a minor, individually and as Successor-in-Interest, by and through his legal guardian, Stevandra Lk Kuanoni, Plaintiffs,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a political subdivision of the State of Nevada; OFFICER KENNETH LOPERA, individually and in his Official Capacity; SERGEANT TRAVIS CRUMRINE, individually and in his Official Capacity; OFFICER MICHAEL TRAN, individually and in his Official Capacity; OFFICER MICHAEL FLORES, individually and in his Official Capacity; and Does 1 through 50, inclusive, Defendants. ACTIVITY DATE PROPOSED DEADLINE

          Federico C. Sayre, Esq. (CA Bar No. 67420) Boris Treyzon, Esq. (CA Bar No. 188893) Darren D. Darwish, Esq. (CA Bar No. 305797) ABIR COHEN TREYZON SALO, LLP Admitted Pro Hac Vice Attorneys for Plaintiffs

          Matthew Q. Callister, Esq. (NV Bar No. 1396) Mitchell S. Bisson, Esq. (NV Bar No. 11920) CALLISTER LAW Attorneys for Plaintiffs

          Craig R. Anderson, Esq. NV Bar No. 6882 MARQUIS AURBACH COFFING

          Daniel R. McNutt, Esq. NV Bar No. 7815 MCNUTT LAW FIRM, P.C.

          STIPULATION AND ORDER TO EXTEND DISCOVERY (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 September 12, 2018. In addition, the parties request that the expert deadline, dispositive motion and pre-trial 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:

         I. DISCOVERY COMPLETED TO DATE

         1. On July 18, 2017, Plaintiffs filed their Complaint. ECF No. 1.

         2. On August 4, 2017, Defendant LVMPD filed their Answer to Plaintiffs' Complaint. ECF No. 7.

         3. On August 25, 2017, the parties entered into a stipulation (and the court ordered) that the discovery regarding Defendant Lopera be limited due to his pending criminal charges. ECF No. 27.

         4. On August 28, 2017, Defendant Lopera filed his Answer to Plaintiffs' Complaint. ECF No. 28.

         5. On September 15, 2017, the parties participated in a FRCP 26(f) meeting.

         6. On September 27, 2017, Defendant LVMPD provided their initial disclosures pursuant to Rule 26.

         7. On September 29, 2017, Plaintiffs provided their initial disclosure statement pursuant to Rule 26.

         8. On September 18, 2017, the Court entered the initial discovery order. ECF No. 30.

         9. On October 10, 2017, Defendant LVMPD served each Plaintiff with written discovery.

         10. On November 7, 2017, Plaintiffs served requests for production of documents on Defendant LVMPD.

         11. On December 7, 2017, Plaintiffs provided their responses to Defendant LVMPD's written discovery.

         12. On December 8, 2017, Defendant LVMPD provided their responses to Plaintiffs' Requests for Production of Documents.

         13. On December 20, 2017, Plaintiffs took the depositions of LVMPD Officers Mike Tran and Ashley Lif. (Officer Tran ...


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