ANDRE M. LAGOMARSINO, ESQ. (#6711) 1 TAYLOR N. JORGENSEN, ESQ. (#16259) CRISTINA A. PHIPPS, ESQ. (#16440) 2 CORY M. FORD, ESQ. (#15042) 3 3005 West Horizon Ridge Pkwy., Suite 241 Henderson, Nevada 89052 4 Telephone: (702) 383-2864 Facsimile: (702) 383-0065 5 aml@lagomarsinolaw.com 6 taylor@lagomarsinolaw.com cristina@lagomarsinolaw.com 7 JULIE RAYE, ESQ. (#10967) 8 8350 W. Sahara Ave., Suite 110 Las Vegas, Nevada 89117 9 Telephone: (702) 478-7600 10 Facsimile: (702) 366-1653 julie@thegracelawfirm.com 11 Attorneys for Plaintiffs 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 JESSICA COLEMAN, an individual; CASE NO: 2:24-CV-00930-APG-MDC 15 ALEISHA GOODWIN, an individual; NORAINE PAGDANGANAN, an 16 individual; and RITA REID, an individual; 17 Plaintiffs, AMENDED STIPULATION AND 18 ORDER TO EXTEND DISCOVERY vs. DEADLINES 19 ROBERT TELLES, an individual; and (5th Request) 20 CLARK COUNTY, a political subdivision of the State of Nevada; 21 22 Defendants. AND ALL RELATED CLAIMS. 23 24 IT IS HEREBY STIPULATED AND AGREED between the parties and their 25 undersigned attorneys that the discovery cut-off date of January 26, 2026, be continued for a 26 period of forty-five (45) days from the Court’s prior Order (ECF No. 94), up to and including 27 March 12, 2026, for the purpose of allowing the parties to complete written discovery, complete 1 the depositions of the remaining parties, experts, and lay witnesses, and any other discovery the 2 parties wish to conduct. 3 I. DISCOVERY COMPLETED TO DATE 4 The parties have completed the following discovery to date: Disclosure of Documents: 5 o The Parties exchanged their initial Rule 26 Disclosures. 6 o Defendant Clark County served its first supplemental disclosure on January 8, 2025. 7 o Defendant Clark County served its second supplemental disclosure on February 14, 2025. 8 o Defendant Clark county served its third supplemental disclosure on February 24, 2025. 9 o Plaintiffs served its first supplemental disclosures on March 25, 2025. 10 o Defendant Clark County served its fourth supplemental disclosures on April 3, 2025. 11 o Plaintiffs served their second supplemental disclosures on May 29, 2025. o Plaintiffs served their third supplemental disclosures on June 24, 2025. 12 o Plaintiffs served their fourth supplemental disclosures on July 15, 2025. o Defendant Clark County served its fifth supplemental disclosures on August 19, 13 2025. 14 o Defendant Clark County served its sixth supplemental disclosures on September 10, 2025. 15 Written Discovery: o Counterclaimant Telles served his first set of requests for admission to Plaintiff 16 Pagdanganan on September 25, 2024. Plaintiff Pagdanganan served her responses on November 6, 2024. On January 15, 2025, Plaintiff Pagdanganan 17 served her supplemental responses to Counterclaimant Telles’ first set of 18 requests for admission. o Plaintiffs served an initial set of discovery (interrogatories, requests for 19 production of documents, and requests for admission) to Defendants Telles and Clark County on December 6, 2024. Counterclaimant Telles served his 20 responses to Plaintiff Goodwin, Coleman, and Pagdanganan’s requests for admission on January 9, 2025. Counterclaimant Telles served his responses to 21 Plaintiff Reid’s requests for admission on January 13, 2025. Counterclaimant 22 Telles served his responses to Plaintiffs requests for production of documents and interrogatories on January 16, 2025. Defendant Clark County served its 23 responses to Plaintiffs requests for admission and interrogatories on February 7, 2025 and served its responses to request for production of documents on 24 February 14, 2025. Defendant Clark County served its first supplemental 25 responses to Plaintiff Reid’s first set of requests for production of documents on April 3, 2025. 26 o Counterclaimant Telles served his first set of requests for production of documents to Defendant Clark County on December 6, 2024. Clark County 27 served its responses on January 6, 2025. On February 14, 2025, Defendant Clark 1 County served its first supplemental responses. 2 o Counterclaimant Telles served his second set of requests for production of documents to Defendant Clark County on January 16, 2025. Defendant Clark 3 County served its responses on March 3, 2025. o Counterclaimant Telles served his first set of requests for production of 4 documents to Plaintiffs on January 16, 2025. Plaintiffs served their responses on March 10, 2025. 5 o Counterclaimant Telles served his first set of requests for admissions to Plaintiff 6 Coleman and Goodwin on March 24, 2025. o Defendant Clark County served its first set of discovery requests 7 (interrogatories, requests for production of documents, and requests for admission) to Plaintiffs on March 26, 2025. 8 o Counterclaimant Telles served his responses to Defendant Clark County’s first set of interrogatories on May 9, 2025. 9 o Plaintiff Goodwin served her responses to Defendant Clark County’s first set of 10 interrogatories and requests for admission on May 22, 2025. o Plaintiff Coleman served her responses to Defendant Clark County’s first set of 11 interrogatories and requests for admission on May 22, 2025. o Plaintiff Pagdanganan served her responses to Defendant Clark County’s first 12 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 13 interrogatories and requests for admission on May 22, 2025. 14 o Plaintiffs Goodwin, Coleman, and Pagdanganan served their responses to Defendant Clark County’s first set of requests for production of documents on 15 May 29, 2025. o Plaintiff Goodwin served her supplemental responses to Defendant Clark 16 County’s first set to interrogatories on May 29, 2025. o Plaintiffs Goodwin and Coleman served their first supplemental responses to 17 Counterclaimant Telles’s first set of interrogatories on June 12, 2025. 18 o Counterclaimant Telles served his first set of requests for admissions to Plaintiff Reid on June 26, 2025. 19 o Counterclaimant Telles served his second set of requests for admissions to Plaintiff Goodwin and first set of requests for admission to Plaintiff Reid on June 20 26, 2025. o Plaintiff Reid served her responses to Clark County’s second set of requests for 21 production on July 15, 2025. 22 o Plaintiff Reid served her responses to Telles’ first set of requests for admissions and Plaintiff Goodwin served her responses to Telles’ second set of requests for 23 admissions on August 8, 2025. o Clark County served its second set of requests for admissions and requests for 24 production of documents to Plaintiffs Reid, Coleman, and Goodwin, its second set of interrogatories to Plaintiff Coleman on August 19, 2025. 25 o Plaintiff served her second set of requests for production of documents to 26 Defendant Clark County on August 28, 2025. o Defendant Clark County served its responses to Reid’s second set of requests for 27 production of documents on September 9, 2025. o Clark County served its first supplemental responses to Plaintiffs Reid, Coleman, 1 and Goodwin’s first set of requests for production of documents on August 19, 2025. 2 o Plaintiff Goodwin served her second supplemental responses to Clark County’s 3 first set of interrogatories on September 10, 2025. o Defendant Clark County served its supplemental responses to Defendant Robert 4 Telles’ first set of requests for production of documents on September 10, 2025. o Defendant Clark County served its second supplemental responses to Reid and 5 Goodwin’s first set of requests for production of documents on September 18, 6 2025. o Plaintiff Reid served her third set of requests for production of documents to 7 Defendant Clark County on September 22, 2025. o Plaintiff Coleman served her responses to Clark County’s second set of requests 8 for admissions and requests for production of documents on October 2, 2025.
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ANDRE M. LAGOMARSINO, ESQ. (#6711) 1 TAYLOR N. JORGENSEN, ESQ. (#16259) CRISTINA A. PHIPPS, ESQ. (#16440) 2 CORY M. FORD, ESQ. (#15042) 3 3005 West Horizon Ridge Pkwy., Suite 241 Henderson, Nevada 89052 4 Telephone: (702) 383-2864 Facsimile: (702) 383-0065 5 aml@lagomarsinolaw.com 6 taylor@lagomarsinolaw.com cristina@lagomarsinolaw.com 7 JULIE RAYE, ESQ. (#10967) 8 8350 W. Sahara Ave., Suite 110 Las Vegas, Nevada 89117 9 Telephone: (702) 478-7600 10 Facsimile: (702) 366-1653 julie@thegracelawfirm.com 11 Attorneys for Plaintiffs 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 JESSICA COLEMAN, an individual; CASE NO: 2:24-CV-00930-APG-MDC 15 ALEISHA GOODWIN, an individual; NORAINE PAGDANGANAN, an 16 individual; and RITA REID, an individual; 17 Plaintiffs, AMENDED STIPULATION AND 18 ORDER TO EXTEND DISCOVERY vs. DEADLINES 19 ROBERT TELLES, an individual; and (5th Request) 20 CLARK COUNTY, a political subdivision of the State of Nevada; 21 22 Defendants. AND ALL RELATED CLAIMS. 23 24 IT IS HEREBY STIPULATED AND AGREED between the parties and their 25 undersigned attorneys that the discovery cut-off date of January 26, 2026, be continued for a 26 period of forty-five (45) days from the Court’s prior Order (ECF No. 94), up to and including 27 March 12, 2026, for the purpose of allowing the parties to complete written discovery, complete 1 the depositions of the remaining parties, experts, and lay witnesses, and any other discovery the 2 parties wish to conduct. 3 I. DISCOVERY COMPLETED TO DATE 4 The parties have completed the following discovery to date: Disclosure of Documents: 5 o The Parties exchanged their initial Rule 26 Disclosures. 6 o Defendant Clark County served its first supplemental disclosure on January 8, 2025. 7 o Defendant Clark County served its second supplemental disclosure on February 14, 2025. 8 o Defendant Clark county served its third supplemental disclosure on February 24, 2025. 9 o Plaintiffs served its first supplemental disclosures on March 25, 2025. 10 o Defendant Clark County served its fourth supplemental disclosures on April 3, 2025. 11 o Plaintiffs served their second supplemental disclosures on May 29, 2025. o Plaintiffs served their third supplemental disclosures on June 24, 2025. 12 o Plaintiffs served their fourth supplemental disclosures on July 15, 2025. o Defendant Clark County served its fifth supplemental disclosures on August 19, 13 2025. 14 o Defendant Clark County served its sixth supplemental disclosures on September 10, 2025. 15 Written Discovery: o Counterclaimant Telles served his first set of requests for admission to Plaintiff 16 Pagdanganan on September 25, 2024. Plaintiff Pagdanganan served her responses on November 6, 2024. On January 15, 2025, Plaintiff Pagdanganan 17 served her supplemental responses to Counterclaimant Telles’ first set of 18 requests for admission. o Plaintiffs served an initial set of discovery (interrogatories, requests for 19 production of documents, and requests for admission) to Defendants Telles and Clark County on December 6, 2024. Counterclaimant Telles served his 20 responses to Plaintiff Goodwin, Coleman, and Pagdanganan’s requests for admission on January 9, 2025. Counterclaimant Telles served his responses to 21 Plaintiff Reid’s requests for admission on January 13, 2025. Counterclaimant 22 Telles served his responses to Plaintiffs requests for production of documents and interrogatories on January 16, 2025. Defendant Clark County served its 23 responses to Plaintiffs requests for admission and interrogatories on February 7, 2025 and served its responses to request for production of documents on 24 February 14, 2025. Defendant Clark County served its first supplemental 25 responses to Plaintiff Reid’s first set of requests for production of documents on April 3, 2025. 26 o Counterclaimant Telles served his first set of requests for production of documents to Defendant Clark County on December 6, 2024. Clark County 27 served its responses on January 6, 2025. On February 14, 2025, Defendant Clark 1 County served its first supplemental responses. 2 o Counterclaimant Telles served his second set of requests for production of documents to Defendant Clark County on January 16, 2025. Defendant Clark 3 County served its responses on March 3, 2025. o Counterclaimant Telles served his first set of requests for production of 4 documents to Plaintiffs on January 16, 2025. Plaintiffs served their responses on March 10, 2025. 5 o Counterclaimant Telles served his first set of requests for admissions to Plaintiff 6 Coleman and Goodwin on March 24, 2025. o Defendant Clark County served its first set of discovery requests 7 (interrogatories, requests for production of documents, and requests for admission) to Plaintiffs on March 26, 2025. 8 o Counterclaimant Telles served his responses to Defendant Clark County’s first set of interrogatories on May 9, 2025. 9 o Plaintiff Goodwin served her responses to Defendant Clark County’s first set of 10 interrogatories and requests for admission on May 22, 2025. o Plaintiff Coleman served her responses to Defendant Clark County’s first set of 11 interrogatories and requests for admission on May 22, 2025. o Plaintiff Pagdanganan served her responses to Defendant Clark County’s first 12 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 13 interrogatories and requests for admission on May 22, 2025. 14 o Plaintiffs Goodwin, Coleman, and Pagdanganan served their responses to Defendant Clark County’s first set of requests for production of documents on 15 May 29, 2025. o Plaintiff Goodwin served her supplemental responses to Defendant Clark 16 County’s first set to interrogatories on May 29, 2025. o Plaintiffs Goodwin and Coleman served their first supplemental responses to 17 Counterclaimant Telles’s first set of interrogatories on June 12, 2025. 18 o Counterclaimant Telles served his first set of requests for admissions to Plaintiff Reid on June 26, 2025. 19 o Counterclaimant Telles served his second set of requests for admissions to Plaintiff Goodwin and first set of requests for admission to Plaintiff Reid on June 20 26, 2025. o Plaintiff Reid served her responses to Clark County’s second set of requests for 21 production on July 15, 2025. 22 o Plaintiff Reid served her responses to Telles’ first set of requests for admissions and Plaintiff Goodwin served her responses to Telles’ second set of requests for 23 admissions on August 8, 2025. o Clark County served its second set of requests for admissions and requests for 24 production of documents to Plaintiffs Reid, Coleman, and Goodwin, its second set of interrogatories to Plaintiff Coleman on August 19, 2025. 25 o Plaintiff served her second set of requests for production of documents to 26 Defendant Clark County on August 28, 2025. o Defendant Clark County served its responses to Reid’s second set of requests for 27 production of documents on September 9, 2025. o Clark County served its first supplemental responses to Plaintiffs Reid, Coleman, 1 and Goodwin’s first set of requests for production of documents on August 19, 2025. 2 o Plaintiff Goodwin served her second supplemental responses to Clark County’s 3 first set of interrogatories on September 10, 2025. o Defendant Clark County served its supplemental responses to Defendant Robert 4 Telles’ first set of requests for production of documents on September 10, 2025. o Defendant Clark County served its second supplemental responses to Reid and 5 Goodwin’s first set of requests for production of documents on September 18, 6 2025. o Plaintiff Reid served her third set of requests for production of documents to 7 Defendant Clark County on September 22, 2025. o Plaintiff Coleman served her responses to Clark County’s second set of requests 8 for admissions and requests for production of documents on October 2, 2025. o Plaintiff Goodwin served her responses to Clark County’s second set of requests 9 for admissions and requests for production of documents on October 2, 2025. 10 o Plaintiff Reid served her responses to Clark County’s second set of requests for admissions and requests for production of documents on October 2, 2025. 11 o Plaintiff Coleman served her responses to Clark County’s second set of interrogatories on October 3, 2025. 12 Depositions o Plaintiffs took the videotaped deposition of Karina Pozniak on September 17, 13 2025. 14 o Plaintiffs took the videotaped deposition Jeff Wells on September 18, 2025. o Plaintiffs’ depositions have been noticed by Defendant Clark County. 15 Noraine Pagdanganan – November 18, 2025 Aleisha Goodwin – November 19, 2025 16 Rita Reid – December 9, 2025 Jessica Coleman – December 10, 2025 17 o Plaintiffs anticipate taking the depositions of the following individuals and are 18 working on obtaining dates from Ely State Prison and the witnesses to schedule for late October and early November: 19 Mike Murphy Letty Bonilla (scheduled for November 6, 2025) 20 Sandra Jeantete (Trujillo) 21 II. DISCOVERY YET TO BE COMPLETED 22 The Parties have yet to complete the following discovery: 23 The depositions of the remaining named parties; 24 o Jessica Coleman, Aleisha Goodwin, Noraine Pagdanganan, and Rita Reid1 25 The depositions of fact witnesses; 26 27 1 These depositions are currently scheduled. 1 o Mike Murphy, Letty Bonilla, and Sandra Jeantete (Trujillo)2 2 Subpoenas duces tecum and the depositions of third party percipient witnesses; 3 Expert witness disclosures and expert witness depositions; 4 Additional written discovery which may include written discovery to one another 5 and/or additional subpoenas to third parties; and 6 Any additional discovery the parties wish to conduct. 7 The Parties reserve the right to conduct additional discovery that is permitted by the 8 Federal Rules of Civil Procedure. 9 III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED 10 While the parties have been diligent in conducting discovery in this matter, the following 11 issues have been unavoidable: 12 Defendant Clark County has noticed all of Plaintiffs’ depositions. However, due to an 13 unforeseen scheduling conflict, the depositions of Plaintiffs Rita Reid and Jessica Coleman must 14 be rescheduled into December. Availability for deposition rescheduling is limited because the 15 Ely State Prison only has one available room with a computer for use by inmates in depositions, 16 so the parties in this case have to work around the Ely State Prison schedule. Because these 17 depositions will occur after the current deadline for initial expert disclosures, additional time is 18 necessary to allow the parties to complete fact discovery before moving forward with expert 19 reports. An extension of the case deadlines will ensure that the expert disclosure process 20 proceeds on a complete factual record and will avoid prejudice to either party. As such, this 21 request for extension is proper and not for the purpose of delay nor is it made in bad faith. 22 IV. LEGAL STANDARDS AND ARGUMENT 23 A. Standard to Extend Discovery Deadlines 24 To prevail on a request to amend a scheduling order under Fed. R. Civ. P. 16(b), a movant 25 must establish good cause for doing so. See Johnson v. Mammoth Recreations, Inc., 975 F.2d 26 27 2 Plaintiffs anticipate no issues in scheduling the depositions of Mike Murphy and Letty Bonilla. Plaintiffs are actively working to serve Sandra Jeantete (Trujillo) with a notice of deposition. 1 || 604, 608-09 (9th Cir. 1992); see also Local Rule 26-3. Good cause to extend discovery cutoffs 2 || exists “if it cannot reasonably be met despite the diligence of the party seeking the extension.” 3 || Jd. at 609. Additionally, all motions or stipulations to extend deadlines set forth in the discovery 4 || plan shall be received by the Court no later than twenty-one (21) days before the expiration of 5 || the subject deadline. Local Rule 26-3. 6 Late motions or stipulations should only be granted if the movant demonstrates that the 7 || failure to act was the result of excusable neglect. Jd. The determination of whether neglect is 8 || excusable depends on at least four factors: (1) the danger of prejudice to the opposing party; (2) 9 || the length of the delay and its potential impact on the proceedings; (3) the reason for the delay; 10 || and (4) whether the movant acted in good faith. Bateman v. U.S. Postal Service, 231 F.3d 1220, 11 1223-24 (9th Cir. 2000). This determination is ultimately an equitable one that takes into account 12 || all the relevant circumstances surrounding the party’s omission. Pioneer Investment Services Co. 13 || v. Brunswick Assoc. Ltd. Partnership, 507 U.S. 380, 395 (1993). 14 B. There Exists Good Cause to Extend Discovery Deadlines in this Case 15 The instant case has five parties: three plaintiffs, one defendant, and one counterclaimant. 16 || Counterclaimant Telles is currently incarcerated and proceeding in this matter pro se, making 17 || communication, document production, and deposition scheduling difficult. The Parties 18 || anticipate at least five (5) party depositions, several depositions of other pertinent fact witnesses, 19 || written discovery directed towards and on behalf of five parties, and two to three (2-3) experts 20 || per party. 21 Currently, the parties are working to schedule depositions in the case. Two depositions 22 || have already been taken by Plaintiffs. Defendant Clark County originally noticed the depositions 23 || for Noraine Pagdanganan, Aleisha Goodwin, Jessica Coleman, and Rita Reid. However, due to 24 || a conflict in defense counsel’s office, the depositions for Jessica Coleman and Rita Reid were 25 || rescheduled for early December 2025. This conflict pushes Plaintiff Coleman’s and Reid’ 26 || depositions past the date of production for initial expert reports. The parties expect that this 27 || testimony will be imperative for expert review and therefore request this short extension.
1 V. PROPOSED EXTENDED DEADLINES Current Proposed 2 Discovery cut-off 1/26/26 Thursday, March 12, 2026 3 4 Deadline to amend pleadings and add parties 10/27/25 Thursday, December 11, 2025 5 Deadline for initial expert disclosures 11/26/25 Monday, January 12, 20263 6 Deadline for rebuttal expert disclosures 12/29/25 Thursday, February 12, 2026 7 Deadline to file dispositive motions 2/24/26 Friday, April 10, 2026 8 Deadline to file pre-trial order 3/26/26 Monday, May 11, 20264, or 30 9 days after the dispositive motions have been decided. 10 … 11 … 12 … 13 … 14 … 15 … 16 … 17 … 18 … 19 … 20 … 21 … 22 … 23 24 25 26 3 This deadline falls on January 10, 2026, which is a Saturday. This deadline is extended to Monday, January 12, 2026, pursuant to FRCP. 27 4 This deadline falls on May 10, 2026, which is a Sunday. This deadline is extended to Monday, May 11, 2026, pursuant to FRCP. 1 Trial is not yet set in this matter and dispositive motions have not yet been filed. 2 || Accordingly, this extension will not delay this case. Since this request is a joint request, no party 3 || will be prejudiced. The extension will allow the parties the necessary time to complete discovery. 4 IT IS SO STIPULATED AND AGREED. 5 DATED this 8™ day of October, 2025. DATED this 8™ day of October, 2025. 6 LAGOMARSINO LAW MARQUIS AURBACH 7 /s/ Taylor N. Jorgensen /s/ Tabetha Steinberg 8 || ANDRE M. LAGOMARSINO, ESQ. (#6711) NICK D. CROSBY, ESQ. (#8996) TAYLOR N. JORGENSEN, ESQ. (#16259) | TABETHA J. STEINBERG, ESQ. (#16756) 9 3005 W. Horizon Ridge Pkwy., #241 10001 Park Run Drive Henderson, Nevada 89052 Las Vegas, Nevada 89145 10 || Telephone: (702) 383-2864 Telephone: (702) 382-0711 Facsimile: (702) 383-0065 Facsimile: (702) 382-5816 11 || Attorneys for Plaintiffs Attorneys for Defendant Clark County 12 | DATED this 8" day of October, 2025. 13 || ROBERT TELLES 14 || /s/ Robert Telles Inmate No. 1290264 15 Ely State Prison 16 PO Box 1989 Ely, NV 89301 17 || Se 18 ORDER IT IS SO ORDERED. □□ 19 Lf JX 0 Hon. ie imilia® D. Cofivillier, III PAED STAA fAGISTRATE JUDGE 21 22 DATED: October 14, 2025 23 24 25 26 27