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Woods v. City of Reno

United States District Court, D. Nevada

July 1, 2019

CATHY WOODS a/k/a ANITA CARTER, by and through her Personal Representative, LINDA WADE, Plaintiff,
v.
CITY OF RENO, NEVADA, LAWRENCE C. DENNISON, DONALD W. ASHLEY, CLARENCE A. “JACKIE” LEWIS, and CALVIN R.X. DUNLAP, Defendants.

          CHRISTOPHER J. HICKS Washoe County District Attorney MICHAEL W. LARGE Nevada State Bar Number 10119 JENNIFER L. GUSTAFSON Nevada State Bar Number 12589 Deputy District Attorneys ATTORNEYS FOR CALVIN R.X. DUNLAP

          Elizabeth Wang, Esq. Loevy & Loevy David Owens, Esq. Loevy & Loevy Edmund Gorman, Jr., Esq. Nevada Bar No. 11518 ATTORNEYS FOR CATHY WOODS

          KARL HALL Reno City Attorney MARK A. HUGHS Deputy City Attorney Nevada Bar No. 5375 ATTORNEYS FOR CITY OF RENO AND LAWRENCE DENNISON

          Edwin Byrd III, Esq. Pettiette, Armand, Dunkelman, Woodley, Byrd & Cromwell, LLP. ATTORNEYS FOR CLARENCE LEWIS AND DONALD ASHLEY

          STIPULATION TO CONDUCT FRCP 35 EXAMINATION

          C. W. HOFFMAN, JR. UNITED STATES MAGISTRATE JUDGE

         IT IS HEREBY STIPULATED AND AGREED by and between the parties hereto, by and through their respective counsel, that Plaintiff Cathy Woods (“Plaintiff”) will submit to a psychiatric examination on July 15, 2019 and a psychological evaluation on August 2, 2019 at 9:00 am at the Cedarbrook Lodge located at 18525 36th Avenue South, Seattle, WA 98188. The mental examination will be conducted by Dr. Ronald Roberts and the psychological evaluation will be conducted by Dr. Charles Saldanha.

         IT IS FURTHER STIPULATED that the parties agree that under Federal Rule of Civil Procedure 35 good cause currently exists for an examination of Plaintiff as it relates to his allegations of mental and emotional injury and distress of a lasting and/or severe nature which she contends was caused by Defendants in this action.

         IT IS FURTHER STIPULATED that the nature, scope, conditions and manner of the examination are to be as follows:

         1. Plaintiff will submit to a mental examination to be conducted by Dr. Roberts, and a psychological evaluation by Dr. Saldanha.

         2. Ronald Roberts, PhD, earned his Ph.D. in Psychology at the California School of Professional Psychology in Berkeley, in 1984. He completed his Fellowship in Neuropsychology at the Veterans Administration Hospital in San Francisco in 1983. He became board certified in Forensic Psychology by the American the American Board of Professional Psychology in 1994. Dr. Roberts is specifically trained in the administration, scoring and interpretation of psychological neurocognitive tests in both clinical and forensic populations. A complete copy of Dr. Roberts' curriculum vitae is attached as Exhibit A.

         3. Dr. Roberts will conduct a psychiatric examination of Plaintiff to assist Defendants and their counsel with regard to understanding Plaintiff's alleged complaints of psychiatric injury and, including the origin, nature, and severity of Plaintiff's alleged mental health injuries, and in turn, prognosis and future treatment needs, if applicable.

         4. Dr. Roberts will conduct specific tests\: the Minnesota Multiphasic Personality Inventory - 2 (MMPI-2), the Personality Assessment Inventory (PAI), a “projective” test, e.g. the Rorschach Inkblot Test, and the Wechsler Adult Intelligence Scale, Fourth Edition (WAIS-IV). The duration of the psychological testing will take approximately four to six (4-6) hours excluding appropriate breaks; additional time will be allowed, if needed. Dr. Roberts reserves the right to subtract tests in response to information that Dr. Roberts may receive about the plaintiff, as well as based upon her performance during the assessment.

         5. Dr. Saldanha will conduct a psychological evaluation of Plaintiff to evaluate the nature and extent of Plaintiff's claims of mental and emotional distress. This evaluation will include the taking of a complete personal history (including family, social, and environmental history), a work history, a medical and psychiatric history including substance abuse history, if any, a history of relationships and traumas and a detailed account of the events which the Plaintiff claims was the cause of her alleged emotional damages. The interview will also include a mental status examination to evaluate her mood, speech, thought processes, and other mental functions.

         6. Neither evaluation will not involve any physical examination. There will be no blood tests or other intrusive medical studies or procedures. The examination will be ...


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