Downes-Covington v. Las Vegas Metropolitan Police Department

Opinion

[MARGARET A. MCLETCHIE, Nevada Bar No. 10931 PIETER M. O’LEARY, Nevada Bar No. 15297 2| |LEO S. WOLPERT, Nevada Bar No. 12658 602 South 10" Street 4 | |Las Vegas, NV 89101 Telephone: (702) 728-5300 / Fax: (702) 425-8220 >| Email: efile @ nvlitigation.com 6 | | Counsel for Plaintiffs 9 | | LANCE DOWNES-COVINGTON, an | Case. No.: 2:20-cv-01790-CDS-DJA individual SOLDADERA SANCHEZ, an 10 | | individual, ROBERT O’BRIEN, an individual, EMILY DRISCOLL, an individual, ALISON | STIPULATION AND ORDER TO KENADY, an individual, TENISHA MARTIN, | EXTEND DEADLINE TO 12 an individual GABRIELA MOLINA, RESPOND LVMPD individual, DEFENDANTS’ OBJECTION TO e 13 Plaintiffs, REPORT AND 14 VS. RECOMMENDATION 15||LAS VEGAS METROPOLITAN POLICE | (FIRST REQUEST) DEPARTMENT, in its official capacity; | [ECF No. 99] 2422 16/|LIEUTENANT KURT MCKENZIE, as an 8 7 individual and in his capacity as a Las Vegas Metropolitan Police Department Officer; 18 OFFICER TABATHA DICKSON, as an individual and in her capacity as a Las Vegas 19 Metropolitan Police Department Officer; 0 CAPTAIN PATRICIA SPENCER, as an individual and in her capacity as a Las Vegas {Metropolitan Police Department Officer; CAPTAIN DORI KOREN, as an individual and 22 lin his capacity as a Las Vegas Metropolitan Police 23 Department Officer; EVAN SPOON, as an individual and in his capacity as a Las Vegas 24 Metropolitan Police Department Officer; JORDAN TURNER, as an individual and in his 25 capacity as a Las Vegas Metropolitan Police 26 | | Department Officer; UNKNOWN OFFICERS 1- 14, as individuals and in their capacity as Las 27 | | Vegas Metropolitan Police Department Officers, 28 Defendants. STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION

1 Pursuant to LR JIA 6-1, Plaintiffs LANCE DOWNES-COVINGTON, SOLDADERA SANCHEZ, ROBERT O’BRIEN, EMILY DRISCOLL, ALISON 3 | |KENADY, TENISHA MARTIN, and GABRIELA MOLINA (collectively “Plaintiffs”) and 4| |Defendants LAS VEGAS METROPOLITAN POLICE DEPARTMENT, LIEUTENANT 5 /KURT MCKENZIE, OFFICER TABATHA DICKSON, CAPTAIN PATRICIA SPENCER, CAPTAIN DORI KOREN, EVAN SPOON, JORDAN TURNER, and 7| |\UNKNOWN OFFICERS 1-14 (collectively “LVWMPD Defendants”), by and through their 8 | |respective counsel, hereby stipulate and request that this Court extend the deadline to file 9 | |Plaintiffs’ Response to LVMPD Defendants’ Opposition to Report and Recommendation 10 | |CECF No. 99) by an additional 14 days, extending the deadline from October 19, 2022 to 11 | |November 2, 2022. This is the first stipulation for extension of time for Plaintiffs to respond 12 | |to LVMPD Defendants’ Opposition. g 13 This Request for an extension of time is not sought for any improper purpose or : 14 | Jother purpose of delay. This request for extension is based upon the following: 15 Counsel for Plaintiff initiated this request due to their scheduling conflicts 16 jincluding, but not limited to, Depositions of Defendant Officers Turner (October 18, 2022) 17 jand Dickson (October 24, 2022) thereby limiting their ability to timely and adequately 18 | |respond to Defendants’ Opposition. 19] /// 20] /// /// /// 23 /// 24] /// 25] /// /// /// 28 | | /// pa STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION

1 WHEREFORE, the parties respectfully request that this Court extend the deadline 2 to file Plaintiffs Response to LVMPD Defendants’ Opposition to Report and 3 [Recommendation up to and including November 2, 2022. 4 DATED this 18" day of October, 2022. DATED this 18" day of October, 2022. 7 9 10 | |4/ Pieter M. O’Leary /s/ Jackie V. Nichols ll Margaret A. McLetchie, NBN 10931 Craig R. Anderson, NBN 6882 Pieter M. O’Leary, NBN 15297 Jackie V. Nichols, NBN 14246 12 | |Leo S. Wolpert, NBN 12658 10001 Park Run Drive 602 South Tenth Street Las Vegas, NV 89145 & 13 | |Las Vegas, NV 89101 Attorneys for Defendants Las Vegas 2 44 Attorneys for Plaintiffs Metropolitan Police Department

gine 10 17 IT IS SO ORDERED 20 / ] 21 LZ

3 wT TRICT JUDGE 24 DATED: October 19, 2022 25 26 27 28 STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO LVMPD DEFENDANTS’ OBJECTION TO REPORT AND RECOMMENDATION