United States District Court, D. Nevada
JAMES IIAMS, individually and AMANDA MATTHEWS, individually, Plaintiffs,
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
COUNSEL LAW GROUP Jared Richards, Esq. Nevada Bar No. 11254
Attorneys for Plaintiffs
STIPULATION TO EXTEND DISCOVERY
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.
COMPLETED TO DATE
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.
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.
YET TO BE COMPLETED
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.
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.
WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED
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.
it is hereby stipulated and respectfully requested that this
Court enter an order as follows: