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 3 MCLETCHIE LAW GROUP, PLLC 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 7 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 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 5 IT IS SO STIPULATED. |DATED this 18" day of October, 2022. DATED this 18" day of October, 2022. 7 8 MCLETCHIE LAW GROUP, PLLC MARQUIS AURBACH 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 18 ORDER 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