ANDRE M. LAGOMARSINO, ESQ. (#6711) TAYLOR N. JORGENSEN, ESQ. (#16259) CRISTINA A. PHIPPS, ESQ. (#16440) CORY M. FORD, ESQ. (#15042) 3005 West Horizon Ridge Pkwy., Suite 241 Henderson, Nevada 89052 Telephone: (702) 383-2864 Facsimile: (702) 383-0065 aml@lagomarsinolaw.com taylor@lagomarsinolaw.com cristina@lagomarsinolaw.com JULIE RAYE, ESQ. (#10967) 8350 W. Sahara Ave., Suite 110 Las Vegas, Nevada 89117 Telephone: (702) 478-7600 Facsimile: (702) 366-1653 julie@thegracelawfirm.com Attorneys for Plaintiffs
DISTRICT OF NEVADA JESSICA COLEMAN, an individual; CASE NO: 2:24-CV-00930-APG-MDC ALEISHA GOODWIN, an individual; NORAINE PAGDANGANAN, an individual; and RITA REID, an individual;
Plaintiffs, STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES vs. (4th Request) ROBERT TELLES, an individual; and CLARK COUNTY, a political subdivision of the State of Nevada;
Defendants.
AND ALL RELATED CLAIMS. IT IS HEREBY STIPULATED AND AGREED between the parties and their undersigned attorneys that the discovery cut-off date of October 28, 2025, be continued for a period of ninety (90) days from the Court’s prior Order (ECF No. 80), up to and including January 26, 2025, for the purpose of allowing the parties to complete written discovery, complete the depositions of the remaining parties, experts, and lay witnesses, and any other discovery the parties wish to conduct. The parties have completed the following discovery to date: • Disclosure of Documents: o The Parties exchanged their initial Rule 26 Disclosures. o Defendant Clark County served its first supplemental disclosure on January 8, 2025. o Defendant Clark County served its second supplemental disclosure on February 14, 2025. o Defendant Clark county served its third supplemental disclosure on February 24, 2025. o Plaintiffs served its first supplemental disclosures on March 25, 2025. o Defendant Clark County served its fourth supplemental disclosures on April 3, 2025. o Plaintiffs served their second supplemental disclosures on May 29, 2025. o Plaintiffs served their third supplemental disclosures on June 24, 2025. • Written Discovery: o Defendant Telles served his first set of requests for admission to Plaintiff Pagdanganan on September 25, 2024. Plaintiff Pagdanganan served her responses on November 6, 2024. On January 15, 2025, Plaintiff Pagdanganan served her supplemental responses to Defendant Telles’ first set of requests for admission. o Plaintiffs served an initial set of discovery (interrogatories, requests for production of documents, and requests for admission) to Defendants Telles and Clark County on December 6, 2024. Defendant Telles served his responses to Plaintiff Goodwin, Coleman, and Pagdanganan’s requests for admission on January 9, 2025. Defendant Telles served his responses to Plaintiff Reid’s requests for admission on January 13, 2025. Defendant Telles served his responses to Plaintiffs requests for production of documents and interrogatories on January 16, 2025. Defendant Clark County served its responses to Plaintiffs requests for admission and interrogatories on February 7, 2025 and served its responses to request for production of documents on February 14, 2025. Defendant Clark County served its first supplemental responses to Plaintiff Reid’s first set of requests for production of documents on April 3, 2025. o Defendant Telles served his first set of requests for production of documents to Defendant Clark County on December 6, 2024. Clark County served its responses on January 6, 2025. On February 14, 2025, Defendant Clark County served its first supplemental responses. o Defendant Telles served his second set of requests for production of documents to Defendant Clark County on January 16, 2025. Defendant Clark County served its responses on March 3, 2025. o Defendant Telles served his first set of requests for production of documents to Plaintiffs on January 16, 2025. Plaintiffs served their responses on March 10, 2025. o Defendant Telles served his first set of requests for admissions to Plaintiff Coleman and Goodwin on March 24, 2025. o Defendant Clark County served its first set of discovery requests (interrogatories, requests for production of documents, and requests for admission) to Plaintiffs on March 26, 2025. o Defendant Telles served his responses to Defendant Clark County’s first set of interrogatories on May 9, 2025. o Plaintiff Goodwin served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Coleman served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Pagdanganan served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Reid served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiffs Goodwin, Coleman, and Pagdanganan served their responses to Defendant Clark County’s first set of requests for production of documents on May 29, 2025. o Plaintiff Goodwin served her supplemental responses to Defendant Clark County’s first set to interrogatories on May 29, 2025. o Plaintiffs Goodwin and Coleman served their first supplemental responses to Defendant Telles’s first set of interrogatories on June 12, 2025. o Defendant Telles served his first set of requests for admissions to Plaintiff Reid on June 26, 2025. o Defendant Telles served his second set of requests for admissions to Plaintiff Goodwin on June 26, 2025. II. DISCOVERY YET TO BE COMPLETED The Parties have yet to complete the following discovery (individual or 30(b)(6) designees); • The depositions of the remaining named parties; • The depositions of fact witnesses; • Subpoenas duces tecum and the depositions of third party percipient witnesses; • Expert witness disclosures and expert witness depositions; • Additional written discovery which may include written discovery to one another and/or additional subpoenas to third parties; and • Any additional discovery the parties wish to conduct. The Parties reserve the right to conduct additional discovery that is permitted by the Federal Rules of Civil Procedure. III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED While the parties have been diligent in conducting discovery in this matter, the following issues have been unavoidable: Given Robert Telles’s status as an incarcerated individual, timely communication has been a challenge. To date, Mr. Telles has largely chosen to communicate via letter, which naturally involves a lag between time of sending and time of arrival. This has impacted discovery requests, responses, production, and general review. Lastly, Telles has had inconsistent access to the law library and limited time to review the discovery produced in this case so far. Additionally, Plaintiffs have sent deposition subpoenas to four (4) fact witnesses and have scheduled them in August. One of the material witnesses, Jeff Wells, is unavailable to have his deposition taken until September. Further, counsel for Plaintiffs and for Defendant Clark County have limited and conflicting availability during July and August, making scheduling difficult. Ultimately, however, the deposition of Jeff Wells needs to be completed prior to the disclosure of expert reports, which are currently due on August 28, 2025. Finally, it is Plaintiffs’ understanding that Defendant Clark County’s counsel is still reviewing a large number of documents for production. These documents are necessary to have prior to depositions of the subpoena-ed witnesses. As such, this request for extension is proper and not for the purpose of delay nor made in bad faith. A. Standard to Extend Discovery Deadlines To prevail on a request to amend a scheduling order under
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ANDRE M. LAGOMARSINO, ESQ. (#6711) TAYLOR N. JORGENSEN, ESQ. (#16259) CRISTINA A. PHIPPS, ESQ. (#16440) CORY M. FORD, ESQ. (#15042) 3005 West Horizon Ridge Pkwy., Suite 241 Henderson, Nevada 89052 Telephone: (702) 383-2864 Facsimile: (702) 383-0065 aml@lagomarsinolaw.com taylor@lagomarsinolaw.com cristina@lagomarsinolaw.com JULIE RAYE, ESQ. (#10967) 8350 W. Sahara Ave., Suite 110 Las Vegas, Nevada 89117 Telephone: (702) 478-7600 Facsimile: (702) 366-1653 julie@thegracelawfirm.com Attorneys for Plaintiffs
DISTRICT OF NEVADA JESSICA COLEMAN, an individual; CASE NO: 2:24-CV-00930-APG-MDC ALEISHA GOODWIN, an individual; NORAINE PAGDANGANAN, an individual; and RITA REID, an individual;
Plaintiffs, STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES vs. (4th Request) ROBERT TELLES, an individual; and CLARK COUNTY, a political subdivision of the State of Nevada;
Defendants.
AND ALL RELATED CLAIMS. IT IS HEREBY STIPULATED AND AGREED between the parties and their undersigned attorneys that the discovery cut-off date of October 28, 2025, be continued for a period of ninety (90) days from the Court’s prior Order (ECF No. 80), up to and including January 26, 2025, for the purpose of allowing the parties to complete written discovery, complete the depositions of the remaining parties, experts, and lay witnesses, and any other discovery the parties wish to conduct. The parties have completed the following discovery to date: • Disclosure of Documents: o The Parties exchanged their initial Rule 26 Disclosures. o Defendant Clark County served its first supplemental disclosure on January 8, 2025. o Defendant Clark County served its second supplemental disclosure on February 14, 2025. o Defendant Clark county served its third supplemental disclosure on February 24, 2025. o Plaintiffs served its first supplemental disclosures on March 25, 2025. o Defendant Clark County served its fourth supplemental disclosures on April 3, 2025. o Plaintiffs served their second supplemental disclosures on May 29, 2025. o Plaintiffs served their third supplemental disclosures on June 24, 2025. • Written Discovery: o Defendant Telles served his first set of requests for admission to Plaintiff Pagdanganan on September 25, 2024. Plaintiff Pagdanganan served her responses on November 6, 2024. On January 15, 2025, Plaintiff Pagdanganan served her supplemental responses to Defendant Telles’ first set of requests for admission. o Plaintiffs served an initial set of discovery (interrogatories, requests for production of documents, and requests for admission) to Defendants Telles and Clark County on December 6, 2024. Defendant Telles served his responses to Plaintiff Goodwin, Coleman, and Pagdanganan’s requests for admission on January 9, 2025. Defendant Telles served his responses to Plaintiff Reid’s requests for admission on January 13, 2025. Defendant Telles served his responses to Plaintiffs requests for production of documents and interrogatories on January 16, 2025. Defendant Clark County served its responses to Plaintiffs requests for admission and interrogatories on February 7, 2025 and served its responses to request for production of documents on February 14, 2025. Defendant Clark County served its first supplemental responses to Plaintiff Reid’s first set of requests for production of documents on April 3, 2025. o Defendant Telles served his first set of requests for production of documents to Defendant Clark County on December 6, 2024. Clark County served its responses on January 6, 2025. On February 14, 2025, Defendant Clark County served its first supplemental responses. o Defendant Telles served his second set of requests for production of documents to Defendant Clark County on January 16, 2025. Defendant Clark County served its responses on March 3, 2025. o Defendant Telles served his first set of requests for production of documents to Plaintiffs on January 16, 2025. Plaintiffs served their responses on March 10, 2025. o Defendant Telles served his first set of requests for admissions to Plaintiff Coleman and Goodwin on March 24, 2025. o Defendant Clark County served its first set of discovery requests (interrogatories, requests for production of documents, and requests for admission) to Plaintiffs on March 26, 2025. o Defendant Telles served his responses to Defendant Clark County’s first set of interrogatories on May 9, 2025. o Plaintiff Goodwin served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Coleman served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Pagdanganan served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiff Reid served her responses to Defendant Clark County’s first set of interrogatories and requests for admission on May 22, 2025. o Plaintiffs Goodwin, Coleman, and Pagdanganan served their responses to Defendant Clark County’s first set of requests for production of documents on May 29, 2025. o Plaintiff Goodwin served her supplemental responses to Defendant Clark County’s first set to interrogatories on May 29, 2025. o Plaintiffs Goodwin and Coleman served their first supplemental responses to Defendant Telles’s first set of interrogatories on June 12, 2025. o Defendant Telles served his first set of requests for admissions to Plaintiff Reid on June 26, 2025. o Defendant Telles served his second set of requests for admissions to Plaintiff Goodwin on June 26, 2025. II. DISCOVERY YET TO BE COMPLETED The Parties have yet to complete the following discovery (individual or 30(b)(6) designees); • The depositions of the remaining named parties; • The depositions of fact witnesses; • Subpoenas duces tecum and the depositions of third party percipient witnesses; • Expert witness disclosures and expert witness depositions; • Additional written discovery which may include written discovery to one another and/or additional subpoenas to third parties; and • Any additional discovery the parties wish to conduct. The Parties reserve the right to conduct additional discovery that is permitted by the Federal Rules of Civil Procedure. III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED While the parties have been diligent in conducting discovery in this matter, the following issues have been unavoidable: Given Robert Telles’s status as an incarcerated individual, timely communication has been a challenge. To date, Mr. Telles has largely chosen to communicate via letter, which naturally involves a lag between time of sending and time of arrival. This has impacted discovery requests, responses, production, and general review. Lastly, Telles has had inconsistent access to the law library and limited time to review the discovery produced in this case so far. Additionally, Plaintiffs have sent deposition subpoenas to four (4) fact witnesses and have scheduled them in August. One of the material witnesses, Jeff Wells, is unavailable to have his deposition taken until September. Further, counsel for Plaintiffs and for Defendant Clark County have limited and conflicting availability during July and August, making scheduling difficult. Ultimately, however, the deposition of Jeff Wells needs to be completed prior to the disclosure of expert reports, which are currently due on August 28, 2025. Finally, it is Plaintiffs’ understanding that Defendant Clark County’s counsel is still reviewing a large number of documents for production. These documents are necessary to have prior to depositions of the subpoena-ed witnesses. As such, this request for extension is proper and not for the purpose of delay nor made in bad faith. A. Standard to Extend Discovery Deadlines To prevail on a request to amend a scheduling order under Fed. R. Civ. P. 16(b), a movant must establish good cause for doing so. See Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608-09 (9th Cir. 1992); see also Local Rule 26-3. Good cause to extend discovery cutoffs exists “if it cannot reasonably be met despite the diligence of the party seeking the extension.” Id. at 609. Additionally, all motions or stipulations to extend deadlines set forth in the discovery plan shall be received by the Court no later than twenty-one (21) days before the expiration of the subject deadline. Local Rule 26-3. Late motions or stipulations should only be granted if the movant demonstrates that the failure to act was the result of excusable neglect. Id. The determination of whether neglect is excusable depends on at least four factors: (1) the danger of prejudice to the opposing party; (2) the length of the delay and its potential impact on the proceedings; (3) the reason for the delay; and (4) whether the movant acted in good faith. Bateman v. U.S. Postal Service, 231 F.3d 1220, 1223-24 (9th Cir. 2000). This determination is ultimately an equitable one that takes into account all the relevant circumstances surrounding the party’s omission. Pioneer Investment Services Co. v. Brunswick Assoc. Ltd. Partnership, 507 U.S. 380, 395 (1993). B. There Exists Good Cause to Extend Discovery Deadlines in this Case The instant case has five parties: three plaintiffs, one defendant, and one counterclaimant. Counterclaimant Telles is currently incarcerated and proceeding in this matter pro se, making communication and document production difficult. At present, there are three motions to dismiss pending before the Court, the outcomes of which will impact the type and extent of discovery conducted in this case. Given the breadth of the claims in this case, discovery will be extensive and costly. The Parties anticipate at least five (5) party depositions, several depositions of other pertinent fact witnesses, written discovery directed towards and on behalf of five parties, and two to three experts per party. The Parties wish to avoid costs associated with discovery that may ultimately determined to be moot because the claims it relates to were dismissed. There are many moving parts to this case which are likely to impact the course of discovery. It is financially prudent for all parties to receive decisions on the pending motions to dismiss. Additionally, there is a massive amount of discovery being produced in this case which requires more time than is currently scheduled to properly review and produce. As such, there is good cause to extend all discovery deadlines. Current Proposed Discovery cut-off 10/28/25 Monday January 26, 2026 Deadline to amend pleadings and add parties 7/29/25 Monday October 27, 2025 Deadline for initial expert disclosures 8/28/25 Wednesday November 26, 2025 Deadline for rebuttal expert disclosures 9/30/25 Monday December 29, 2025 Deadline to file dispositive motions 11/26/25 Tuesday February 24, 2026 Deadline to file pre-trial order 12/26/25 Thursday March 26, 2026, or 30 days after the dispositive motions have been decided.
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Trial is not yet set in this matter and dispositive motions have not yet been filed. Accordingly, this extension will not delay this case. Since this request is a joint request, no party will be prejudiced. The extension will allow the parties the necessary time to complete discovery. DATED this 10" day of July, 2025. DATED this 10" day of July, 2025. LAGOMARSINO LAW MARQUIS AURBACH /s/ Taylor N. Jorgensen /s/ Tabetha J. Stemberg ANDRE M. LAGOMARSINO, ESQ. (#6711) NICK D. CROSBY, ESQ. (#8996) TAYLOR N. JORGENSEN, ESQ. (#16259) | TABETHA J. STEINBERG, ESQ. (#16756) 3005 W. Horizon Ridge Pkwy., #241 10001 Park Run Drive Henderson, Nevada 89052 Las Vegas, Nevada 89145 Telephone: (702) 383-2864 Telephone: (702) 382-0711 Facsimile: (702) 383-0065 Facsimile: (702) 382-5816 Attorneys for Plaintiffs Attorneys for Defendant Clark County DATED this 10% day of July, 2025. ROBERT TELLES /s/ Robert Telles Inmate No. 1290264 I5 High Desert State Prison PO Box 650 Indian Springs, NV 89070 Pro Se Any future extension request must include firm dates for any remaining depositions and more detailed discussion of any other remaining discovery. / Mp7 a % Hon. MaximilianoD. ouvillist If United StatesMagistrate Juage 54 DATED:7 4/25
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Pursuant to FRCP 5(b), I hereby certify that on this this 10" day of July, 2025, I served a true and correct copy of the foregoing STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (4th Request) on all parties to this action, via CM/ECF and U.S. Mail, to the following: Nicholas Crosby, Esq. Tabetha J. Steinberg, Esq. MARQUIS AURBACH ncrosby@maclaw.com smong@maclaw.com tsteinberg@maclaw.com jmadsen@maclaw.com Attorneys for Defendant Clark County And via U.S. Mail, to the following: ROBERT TELLES 1 Inmate No. 1290264 High Desert State Prison PO Box 650 Indian Springs, NV 89070 Pro Se
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