United States District Court, D. Nevada
CATHY WOODS a/k/a ANITA CARTER, by and through her Personal Representative, LINDA WADE, Plaintiff,
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
HALL Reno City Attorney MARK A. HUGHS Deputy City Attorney
Nevada Bar No. 5375 ATTORNEYS FOR CITY OF RENO AND LAWRENCE
Byrd III, Esq. Pettiette, Armand, Dunkelman, Woodley, Byrd
& Cromwell, LLP. ATTORNEYS FOR CLARENCE LEWIS AND DONALD
STIPULATION TO CONDUCT FRCP 35 EXAMINATION
HOFFMAN, JR. UNITED STATES MAGISTRATE JUDGE
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.
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.
IS FURTHER STIPULATED that the nature, scope,
conditions and manner of the examination are to be as
Plaintiff will submit to a mental examination to be conducted
by Dr. Roberts, and a psychological evaluation by Dr.
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
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
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
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.
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 ...