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, an| OBJECT TO DEFENDANTS’ individual, MOTION TO DISMISS 13 Plaintiffs, OFFICER EVAN SPOON AND 2 44 VS. OFFICER JORDAN TURNER [ECF No. 106] AND (2) 15||LAS VEGAS METROPOLITAN POLICE | DEFENDANTS’ MOTION FOR DEPARTMENT, in its official capacity; | PARTIAL DISMISSAL OF 16||LIEUTENANT KURT MCKENZIE, as an| OFFICER TABATHA DICKSON 8 7 individual and in his capacity as a Las Vegas | [ECF No. 108] Metropolitan Police Department Officer; 18||OFFICER TABATHA DICKSON, as an} (FIRST REQUEST) individual and in her capacity as a Las Vegas 19 Metropolitan Police Department Officer; 20 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 (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN

1 Pursuant to LR JIA 6-1, Plaintiffs LANCE DOWNES-COVINGTON, 2||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, 6 | |CAPTAIN DORI KOREN, OFFICER EVAN SPOON, OFFICER JORDAN TURNER, and 7| |\UNKNOWN OFFICERS 1-14 (collectively “LVMPD Defendants”), by and through their 8 | |respective counsel, hereby stipulate and request that this Court extend the deadline to file 9 | |Plaintiffs’ Objection to (1) LVMPD Defendants’ Motion to Dismiss Officer Spoon and 10 | |Officer Turner (ECF No. 106) and (2) LVMPD Defendants’ Motion for Partial Dismissal as 11 | |to Officer Dickson (ECF No. 108) by an additional 14 days, extending the deadline from 12 | |October 27, 2022 to November 10, 2022. This is the first stipulation for extension of time for g 13 | |Plaintiffs to Object to LVMPD Defendants’ two Motions to Dismiss. 14 This Request for an extension of time is not sought for any improper purpose or 15 | |other purpose of delay. This request for extension is based upon the following: 16 Counsel for Plaintiff initiated this request due to their scheduling conflicts 2 17 | jincluding, but not limited to, Depositions of Defendant Officers Turner (October 18, 2022), 18 | |Dickson (October 24, 2022), Spoon (November 7, 2022) as well as the deadline to Respond 19 | |to LVMPD Defendants’ Objection to Report and Recommendation (ECF No. 99) thereby 20 | |limiting their ability to timely and adequately object to LVMPD Defendants’ two Motions. /// /// 23 || /// 24] | /// 25] | /// /// | /// 28 | | /// pa STIPULATION AND ORDER TO (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN

1 WHEREFORE, the parties respectfully request that this Court extend the deadline 2 | |to file Plaintiffs’ Objection to LVMPD Defendants’ two Motions to Dismiss up to and 3 | |including November 10, 2022. 4 5 IT IS SO STIPULATED. 6 | |DATED this 26" day of October, 2022. DATED this 26" 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 10" Street Las Vegas, NV 89145 & 13 | |Las Vegas, NV 89101 Attorneys for Defendants Las Vegas 2 44 Attorneys for Plaintiffs Metropolitan Police Department, et al.

gine 10 © 17 18 ORDER 19 IT IS SO ORDERED. 20 ) 21 22 [er 3 US. DI TRICT JUDGE 24 DATED: November 1, 2022 25 26 27 28

STIPULATION AND ORDER TO (1) EXTEND DEADLINE TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OFFICER EVAN SPOON AND OFFICER JORDAN