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Iiams v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

July 11, 2018

JAMES IIAMS, individually and AMANDA MATTHEWS, individually, Plaintiffs,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a political subdivision of the State of Nevada; SERGEANT JUSTIN BRYERS; OFFICER RICHARD NELSON; OFFICER JONATHAN CARRINGTON; OFFICER LUKAS FERRIS; and DOE OFFICERS I-XX, Defendants.

          KAEMPFER CROWELL LYSSA S. ANDERSON Nevada Bar No. 5781 RYAN W. DANIELS Nevada Bar No. 13094 Attorneys for Defendant

          CLEAR COUNSEL LAW GROUP Jared Richards, Esq. Nevada Bar No. 11254 Attorneys for Plaintiffs

          STIPULATION TO EXTEND DISCOVERY

         Defendant Las Vegas Metropolitan Police Department (“LVMPD”), by and through its counsel, Lyssa Anderson, Esq., of the law firm of Kaempfer Crowell, and James Iiams and Amanda Matthews (“Plaintiffs”), by and through their counsel, Jared Richards, Esq. of Clear Counsel Law Group hereby stipulate and agree that the discovery cut-off date of September 4, 2018, be continued for a period of ninety (90) days up to and including December 3, 2018, for the purpose of allowing the newly named Defendants to be served and respond to the Amended Complaint, to allow the parties to complete written discovery, to retain and disclose expert witnesses, and to take depositions of the parties and third-party witnesses.

         DISCOVERY COMPLETED TO DATE

         Defendant, LAS VEGAS METROPOLITAN POLICE DEPARTMENT, (“LVMPD”) has provided its initial Rule 26(f) Disclosures and its First Supplement to Rule 26 Disclosures to Plaintiffs. Plaintiffs have provided their Rule 26 Disclosures to LVMPD.

         LVMPD served its First Interrogatories on Plaintiffs which were responded to. LVMPD also served Requests for Admissions and Requests for Production of Documents on each Plaintiff. Those responses are currently due July 19, 2018 and July 26, 2018.

         DISCOVERY YET TO BE COMPLETED

         Plaintiffs were recently given leave to file an Amended Complaint adding several individual LVMPD Officers as Defendants. The Amended Complaint was filed on July 2, 2018 and Summonses were issued for the individual Officers. Plaintiffs have not yet served the newly named Defendants and LVMPD has not filed a response to the Amended Complaint.

         Plaintiffs will respond to the outstanding Requests for Admissions and Requests for Production of Documents by LVMPD. Plaintiffs will serve written discovery on LVMPD and the newly named Defendants once they make an appearance in the case. The parties will provide additional documents and will take the depositions of the named parties and possibly some third-party witnesses. The parties will retain expert witnesses and disclose expert reports.

         REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED

         As set out above, the Plaintiffs were recently permitted by the Court to amend their Complaint to add additional Defendants. The newly named Defendants have not yet been served and have not yet made an appearance. With the addition of new Defendants, the scope of discovery has changed. The parties have been diligent in engaging in discovery, however, based upon the procedural history, the parties require additional time to conduct discovery.

         PROPOSED EXTENDED DEADLINES

         Accordingly, it is hereby stipulated and respectfully requested that this Court enter an order as follows:

         (A) ...


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