Downes-Covington v. Las Vegas Metropolitan Police Department

Opinion

1} |MARGARET A. MCLETCHIE, Nevada Bar No. 10931 PIETER M. O’LEARY, Nevada Bar No. 15297 |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 S| Email: efile@nvlitigation.com 6 | | Counsel for Plaintiffs 7 UNITED STATES DISTRICT COURT g DISTRICT OF NEVADA g | | 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 DISCOVERY PLAN 12| {an individual GABRIELA MOLINA, AND SCHEDULING ORDER individual, DEADLINES 13 Plaintiffs, 5 2 14 vs. (TENTH REQUEST) 15||LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; 16/|LIEUTENANT KURT MCKENZIE, as an 17 individual and in his capacity as a Las Vegas Metropolitan Police Department Officer; |OFFICER TABATHA DICKSON, as an individual and in her capacity as a Las Vegas 19 Metropolitan Police Department Officer; 99 | |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 33 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. pt STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 IT IS HEREBY STIPULATED AND AGREED between Plaintiffs LANCE 2 | |DOWNES-COVINGTON, SOLDADERA SANCHEZ, ROBERT O’BRIEN, EMILY 3 | |DRISCOLL, ALISON KENADY, TENISHA MARTIN, and GABRIELA MOLINA 4 | |\(collectively “Plaintiffs”) and Defendants LAS VEGAS METROPOLITAN POLICE 5 | |DEPARTMENT, LIEUTENANT KURT MCKENZIE, OFFICER TABATHA DICKSON, 6 | |CAPTAIN PATRICIA SPENCER, CAPTAIN DORI KOREN, EVAN SPOON, JORDAN 7| |TURNER, and UNKNOWN OFFICERS 1-14 (collectively “LVMPD Defendants”), by and 8 | {through their respective counsel, that the discovery cut-off date of July 3, 2023, (and related 9 | |deadlines) be extended for a period of sixty (60) days. This Stipulation is being entered in 10 | |good faith and not for the purposes of delay (supplemented information noted in bold-face 11 | |type). 12)| J. STATUS OF DISCOVERY. og A. PLAINTIFFS’ DISCOVERY. 1. Plaintiffs’ Initial Disclosure of Witnesses and Documents Pursuant to FRCP 6 26.1(a)(1) dated January 20, 2021; 2. Plaintiff Lance Downes-Covington’s Responses to LVMPD’s First Set of Interrogatories dated May 13, 2021; 19 3. Plaintiff Soldadera Sanchez’s Responses to LVMPD’s First Set of 0 Interrogatories dated May 13, 2021; 1 4. Plaintiff Robert O’Brien’s Responses to LVYMPD’s First Set of 97 | [Interrogatories dated May 13, 2021; 23 5. Plaintiff Emily Driscoll’s Responses to LVMPD’s First Set of 24 | |Interrogatories dated May 13, 2021; 25 6. Plaintiff Alison Kenady’s Responses to LVMPD’s First Set of 26 | |Interrogatories dated May 13, 2021; 27 7. Plaintiff Tenisha Martin’s Responses to LVMPD’s First Set of 28 Interrogatories dated May 13, 2021; pt STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 8. Plaintiff Gabriela Molina’s Responses to LVMPD’s First Set of 2 | |Interrogatories dated May 13, 2021; 3 9. Plaintiff Lance Downes-Covington’s Responses to LVMPD’s First Set □□ 4 Requests for Production of Documents dated May 13, 2021; 5 10. Plaintiff Soldadera Sanchez’s Responses to LVMPD’s First Set of Requests 6 for Production of Documents dated May 13, 2021; 11. Plaintiff Robert O’Brien’s Responses to LVMPD’s First Set of Requests for 8 Production of Documents dated May 13, 2021; ° 12. Plaintiff Emily Driscoll’s Responses to LVMPD’s First Set of Requests for Production of Documents dated May 13, 2021; 1 13. Plaintiff Alison Kenady’s Responses to LVMPD’s First Set of Requests for

- 2B Production of Documents dated May 13, 2021; 5 14 14. Plaintiff Tenisha Martin’s Responses to LVMPD’s First Set of Requests for 15 Production of Documents dated May 13, 2021; 16 15. Plaintiff Gabriela Molina’s Responses to LVMPD’s First Set of Requests 17 | |for Production of Documents dated May 13, 2021; 18 16. Plaintiff Lance Downes-Covington’s First Set of Interrogatories to LVMPD 19 | |dated June 2, 2021; 20 17. Plaintiffs’ First Set of Requests for Production of Documents to LVMPD 21 | |dated June 2, 2021; 22 18. Plaintiff Emily Driscoll’s First Set of Interrogatories to LVMPD dated July 23111, 2021; 24 19. Plaintiffs’ First Supplement to Initial Disclosure of Witnesses and 25 Documents Pursuant to FRCP 26.1(a)(1) dated July 1, 2021; 26 20. Plaintiffs’ Second Supplement to Initial Disclosure of Witnesses and Documents Pursuant to FRCP 26.1(a)(1) dated July 8, 2021; STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 21. Plaintiffs’ Third Supplement to Initial Disclosure of Witnesses and 2 | |Documents Pursuant to FRCP 26.1(a)(1) dated July 12, 2021; 3 22. Plaintiff Soldadera Sanchez’s Supplemental Responses to LVMPD’s First 4] | Set of Interrogatories dated July 8, 2021; 5 23. Plaintiff Robert O’Brien’s Supplemental Responses to LVMPD’s First Set 6 of Interrogatories dated July 8, 2021; 24. Plaintiff Emily Driscoll’s Supplemental Responses to LVMPD’s First Set of Interrogatories dated July 8, 2021; ° 25. Plaintiff Alison Kenady’s Supplemental Responses to LVMPD’s First Set of Interrogatories dated July 8, 2021; 1 26. Plaintiff Tenisha Martin’s Supplemental Responses to LVMPD’s First Set

- 2B of Interrogatories dated June 8, 2021; Bs 14 27. Plaintiff Soldadera Sanchez’s Supplemental Responses to LVMPD’s First 15 Set of Requests for Production of Documents dated July 8, 2021; 16 28. Plaintiff Robert O’Brien’s Supplemental Responses to LVMPD’s First Set 17 | |of Requests for Production of Documents dated July 8, 2021; 18 29. Plaintiff Emily Driscoll’s Supplemental Responses to LVMPD’s First Set 19 | |of Requests for Production of Documents dated July 8, 2021; 20 30. Plaintiff Alison Kenady’s Supplemental Responses to LVMPD’s First Set 21 | |of Requests for Production of Documents dated July 8, 2021; 22 31. Plaintiff Tenisha Martin’s Supplemental Responses to LVMPD’s First Set | of Requests for Production of Documents dated July 8, 2021; 24 32. Plaintiff Gabriela Molina’s Supplemental Responses to LVMPD’s First Set 25 of Requests for Production of Documents dated July 8, 2021; 26 33. Plaintiff Gabriela Molina’s Second Supplemental Responses to LVMPD’s First Set of Requests for Production of Documents dated July 12, 2021;

pS STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 34. Plaintiff Lance Downes-Covington’s Supplemental Responses to 2 | |LVMPD’s First Set of Requests for Production of Documents dated July 12, 2021; 3 35. Plaintiff Gabriela Molina’s Supplemental Responses to LVMPD’s First Set 4] lof Interrogatories dated July 12, 2021; 5 36. Plaintiff Lance Downes-Covington’s Supplemental Responses to 6 LVMPD’s First Set of Interrogatories dated July 12, 2021; 37. Plaintiff Tenisha Martin’s First Set of Interrogatories to LVMPD dated July 13, 2021; ° 38. Plaintiffs’ Second Set of Requests for Production of Documents to LVMPD dated July 13, 2021; 1 39. Plaintiff Tenisha Martin’s Second Set of Interrogatories to LVMPD dated

2B July 14, 2021; 2 14 40. Plaintiffs’ Third Set of Requests for Production of Documents to LVMPD 15 dated July 14, 2021; 16 41. Plaintiffs’ Fourth Supplement to Initial Disclosure of Witnesses and 17 | |Documents Pursuant to FRCP 26.1(a)(1) dated September 15, 2021; 18 42. Plaintiff Tenisha Martin’s Third Set of Interrogatories to LVMPD dated 19 | |September 15, 2021; 20 43. Plaintiffs’ Fourth Set of Requests for Production of Documents to LVMPD 21] dated September 15, 2021; 22 44. Plaintiffs’ First Set of Requests for Admission to LVMPD dated September 231117, 2021; 24 45. Tenisha Martin’s Responses to Lt. Kurt McKenzie’s First Set of 25 Interrogatories dated December 16, 2021; 26 46. Soldadera Sanchez’s Responses to Lt. Kurt McKenzie’s First Set of a Interrogatories dated December 16, 2021; 28 pS STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 47. Robert O’ Brien’s Responses to Lt. Kurt McKenzie’s First Set of 2 Interrogatories dated December 16, 2021; 3 48. Lance Downes-Covington’s Responses to Lt. Kurt McKenzie’s First Set of 4 Interrogatories dated December 16, 2021; 5 49. Gabriela Molina’s Responses to Lt. Kurt McKenzie’s First Set of 6 Interrogatories dated December 16, 2021; 50. Emily Driscoll’s Responses to Lt. Kurt McKenzie’s First Set of 8 Interrogatories dated December 16, 2021; ° 51. Alison Kenady’s Responses to Lt. Kurt McKenzie’s First Set of Interrogatories dated December 16, 2021; 1 52. Tenisha Martin’s Responses to LVMPD’s First Set of Requests for

- 2B Admissions dated December 16, 2021; 14 53. Soldadera Sanchez’s Responses to LVMPD’s First Set of Requests for 15 Admissions dated December 16, 2021; 16 54. Robert O’Brien’s Responses to LVMPD’s First Set of Requests for 17 | |Admissions dated December 16, 2021; 18 55. Lance Downes-Covington’s Responses to LVMPD’s First Set of Requests 19 | | for Admissions dated December 16, 2021; 20 56. Gabriela Molina’s Responses to LVMPD’s First Set of Requests for | Admissions dated December 16, 2021; 22 57. Emily Driscoll’s Responses to LVMPD’s First Set of Requests for 23 | | Admissions dated December 16, 2021; 24 58. Alison Kenady’s Responses to LVMPD’s First Set of Requests for 25 Admissions dated December 16, 2021; 26 59. Alison Kenady’s First Set of Interrogatories to LVMPD dated April 1, 2022; 27 28 pt STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 60. Emily Driscoll’s Second Set of Interrogatories to LVMPD dated April 1, 2 | |2022; 3 61. Gabriella Molina’s First Set of Interrogatories to LVMPD dated April 1, 41 12022; 5 62. Lance Downes-Covington’s Second Set of Interrogatories to LVMPD dated 6 April 1, 2022; 63. Plaintiffs’ Fifth Set of Requests for Production of Documents to LYVMPD 8 dated April 1, 2022; ° 64. Robert O’Brien’s First Set of Interrogatories to LVMPD dated April 1, 2022; 1 65. Plaintiffs’ Second Set of Requests for Admissions to LVMPD dated April

B 1, 2022; 2 14 66. Sol Sanchez’s First Set of Interrogatories to LVMPD dated April 1, 2022; 15 67. Plaintiffs’ First Set of Requests for Production of Documents to Defendant 16 | |Joe Lombardo [Request Nos. 1-5] dated June 17, 2022; 17 68. Plaintiffs’ First Set of Requests for Admissions to Defendant Tabatha 18 | | Dickson dated June 17, 2022; 19 69. Plaintiffs’ First Set of Requests for Production of Documents to Defendant 20 | | Joe Lombardo [Request Nos. 1-4] dated June 17, 2022; 21 70. Soldadera Sanchez’s Second Set of Interrogatories to LVMPD dated June 22 2022; 23 71. Robert O’Brien’s Second Set of Interrogatories to LVMPD dated June 17, 24 |9022; 2 72. Emily Driscoll’s Third Set of Interrogatories to LVMPD dated June 17, 26 2022; 27 28 pT STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 73. Lance Downes-Covington’s Third Set of Interrogatories to LVMPD dated 2 | |June 17, 2022; 3 74. Plaintiffs’ Sixth Set of Requests for Production of Documents to LVMPD 4 | | dated June 17, 2022; 5 75. Plaintiffs’ Third Set of Requests for Admissions to LVMPD dated June 17, 6 2022; 7 76. Tenisha Martin’s Fourth Set of Interrogatories to LVMPD dated June 17, 8 2022; 9 77. Lance Downes-Covington’s First Set of Interrogatories to Officer Tabatha 10 Dickson dated June 17, 2022; 1 78. Soldadera Sanchez’s First Set of Interrogatories to Joe Lombardo dated

2B June 17, 2022; 2 14 79. Soldadera Sanchez’s First Set of Interrogatories to Lt. Kurt McKenzie dated 15 | [June 17, 2022; 16 80. Plaintiffs’ First Set of Requests for Production of Documents to Defendant

= |Patricia Spencer dated June 17, 2022; 18 81. Plaintiffs’ First Set of Requests for Production of Documents to Defendant 19 | |Dori Koren dated June 17, 2022; 20 82. Plaintiffs’ First Set of Requests for Production of Documents to Joe |Lombardo [Request No. 1] dated June 17, 2022; 22 83. Plaintiffs’ First Set of Requests for Production of Documents to Lt. Kurt 23 | |McKenzie dated June 17, 2022; 24 84. Tenisha Martin’s First Set of Interrogatories to Lt. Kurk McKenzie dated 25 June 17, 2022; 26 85. Plaintiffs’ Third Set of Requests for Admissions to LVMPD dated June 21, 27 2022; 28 pt STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 86. Plaintiffs’ Sixth Set of Requests for Production of Documents to LVMPD 2 | |dated June 21, 2022; 3 87. Emily Driscoll’s Third Set of Interrogatories to LVMPD dated June 21, 41 12022; 5 88. Lance Downes-Covington’s Third Set of Interrogatories to LVMPD dated 6 June 21, 2022; 7 89. Robert O’Brien’s Second Set of Interrogatories to LVMPD dated June 21, 8 2022; 9 90. Soldadera Sanchez’s First Set of Interrogatories to Lt. Kurt McKenzie dated 10 June 21, 2022; 1] 1 91. Soldadera Sanchez’s First Set of Interrogatories to Joe Lombardo dated

13 June 21, 2022; 2 14 92. Soldadera Sanchez’s Second Set of Interrogatories to LVMPD dated June 15 | [21 2022; 16 93. Plaintiffs’ First Set of Requests for Admissions to Officer Tabatha Dickson

= |dated June 21, 2022; 18 94. Plaintiffs’ First Set of Requests for Production of Documents to Joe 19 | |Lombardo [Request Nos. 1-5] dated June 21, 2022; 20 95. Plaintiffs’ First Set of Requests for Production of Documents to Lt. Kurt 21 | |McKenzie dated June 21, 2022; 22 96. Plaintiffs’ First Set of Requests for Production of Documents to Officer 23 | |Tabatha Dickson dated June 21, 2022; 24 97. Plaintiffs’ First Set of Requests for Production of Documents to Patricia 25 Spencer dated June 21, 2022; 26 98. Plaintiffs’ First Set of Requests for Production of Documents to Captain 27 Dori Koren dated June 21, 2022; 28 pt STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 99. Lance Downes-Covington’s First Set of Interrogatories to Officer Tabatha 2 | |Dickson dated June 21, 2022; 3 100. Tenisha Martin’s First Set of Interrogatories to Lt. Kurt McKenzie dated 41 June 21, 2022; 5 101. Tenisha Martin’s Fourth Set of Interrogatories to LVMPD dated June 21, 6 2022; 102. Plaintiff Emily Driscoll’s Requests for Admissions to LVMPD - Set One 8 dated October 27, 2022. ° 103. Plaintiff Emily Driscoll’s Interrogatories to LVMPD - Set Four dated October 27, 2022.

1 104. Plaintiff Emily Driscoll’s Interrogatories to Tabatha Dickson - Set One

- 2B dated October 27, 2022. Bs 14 105. Plaintiff Emily Driscoll’s Requests for Production of Documents to 15 LVMPD - Set One dated October 27, 2022. : 16 106. Plaintiff Emily Driscoll’s Requests for Production of Documents to Tabatha = 17 | | Dickson - Set One dated October 27, 2022. 18 107. Plaintiff Emily Driscoll’s Requests for Admissions to Tabatha Dickson - 19 | |Set One dated October 27, 2022. 20 108. Plaintiff Gabriela Molina’s Interrogatories to LVMPD - Set Two dated 21 | | October 27, 2022. 22 109. Plaintiff Gabriela Molina’s Interrogatories to Tabatha Dickson - Set One | dated October 27, 2022. 24 110. Plaintiff Gabriela Molina’s Requests for Production of Documents to 25 LVMPD - Set One dated October 27, 2022. 26 111. Plaintiff Gabriela Molina’s Requests for Production of Documents to a Tabatha Dickson - Set One dated October 27, 2022. 28 10 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 112. Plaintiff Gabriela Molina’s Requests for Admissions to LVMPD - Set One 2 | |dated October 27, 2022. 3 113. Plaintiff Gabriela Molina’s Requests for Admissions to Tabatha Dickson - 4 Set One dated October 27, 2022. 5 114. Plaintiff Lance Downes-Covington’s Interrogatories to LVMPD - Set Four 6 dated October 27, 2022. 115. Plaintiff Lance Downes-Covington’s Interrogatories to Tabatha Dickson - 8 Set Two dated October 27, 2022. ° 116. Plaintiff Lance Downes-Covington’s Interrogatories to Jordan Turmer - Set One dated October 27, 2022.

1 117. Plaintiff Lance Downes-Covington’s Requests for Production of

- 2B Documents to LVMPD - Set One dated October 27, 2022. 5 14 118. Plaintiff Lance Downes-Covington’s Requests for Production of 15 Documents to Tabatha Dickson - Set One dated October 27, 2022. 16 119. Plaintiff Lance Downes-Covington’s Requests for Production of = 17 | |Documents to Jordan Turner - Set One dated October 27, 2022. 18 120. Plaintiff Lance Downes-Covington’s Requests for Admissions to LVMPD 19 | |- Set One dated October 27, 2022. 20 121. Plaintiff Lance Downes-Covington’s Requests for Admissions to Tabatha |Dickson - Set One dated October 27, 2022. 22 122. Plaintiff Lance Downes-Covington’s Requests for Admissions to Jordan 23 | |Tumer - Set One dated October 27, 2022. 24 123. Soldadera Sanchez’s Requests for Production of Documents to LVMPD - 25 Set One dated November 7, 2022. 26 124. Soldadera Sanchez’s Requests for Admissions to LVMPD - Set One dated a November 7, 2022. 28 1] STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 125. Robert O’Brien’s Interrogatories to LVMPD - Set One dated November 7, 2 | |2022. 3 126. Robert O’Brien’s Requests for Production of Documents to LVMPD - Set 4 One dated November 7, 2022. 5 127. Robert O’Brien’s Requests for Admissions to LVMPD - Set One dated 6 November 7, 2022. 128. Alison Kenady’s Interrogatories to LVMPD - Set Two dated November 7, 2022. ° 129. Alison Kenady’s Requests for Production of Documents to LVMPD - Set One dated November 7, 2022.

1 130. Alison Kenady’s Requests for Admissions to LVMPD - Set One dated

- 2B November 7, 2022. Bs 14 131. Tenisha Martin’s Requests for Production of Documents to LVMPD - Set 15 One dated November 7, 2022. 16 132. Tenisha Martin’s Requests for Admissions to LVMPD - Set One dated 17 | |November 7, 2022. 18 133. Plaintiffs’ Fifth Supplement to Initial Disclosure of Witnesses and 19 | |Documents Pursuant to FRCP 26.1(a)(1) dated January 4, 2023; 20 134. Plaintiffs’ Sixth Supplement to Initial Disclosure of Witnesses and 21 | |Documents Pursuant to FRCP 26.1(a)(1) dated January 20, 2023. 22 135. Tenisha Martin’s Requests for Production of Documents to LVMPD — Set 23 Two, dated January 17, 2023 24 136. Tenisha Martin’s Requests for Production of Documents to LVMPD — 25 Set Three, dated April 18, 2023. 26 27 28 12 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 B. DEFENDANTS’ DISCOVERY. 2 1. LVMPD Defendants’ Initial Disclosure of Witnesses and Documents 3 | |Pursuant to FRCP 26.1(a)(1) dated January 20, 2021. 4 2. LVMPD’s First Set of Interrogatories to Plaintiff Lance Downes-Covington 5 | |dated March 12, 2021. 6 3. LVMPD’s First Set of Interrogatories to Plaintiff Soldadera Sanchez dated |March 12, 2021. 8 4. LVMPD’s First Set of Interrogatories to Plaintiff Robert O’Brien dated 9 | |March 12, 2021. 10 5. LVMPD’s First Set of Interrogatories to Plaintiff Emily Driscoll dated M March 12, 2021. 2 6. LVMPD’s First Set of Interrogatories to Plaintiff Alison Kenady dated March 12, 2021. 7. LVMPD’s First Set of Interrogatories to Plaintiff Tenisha Martin dated EES: March 12, 2021. 3 7 8. LVMPD’s First Set of Interrogatories to Plaintiff Gabriela Molina dated 18 March 12, 2021. 19 9. LVMPD’s First Set of Request for Production of Documents to Plaintiff 20 | | Lance Downes-Covington dated March 12, 2021. 2] 10. LVMPD’s First Set of Request for Production of Documents to Plaintiff 22 | |Soldadera Sanchez dated March 12, 2021. 23 11. LVMPD’s First Set of Request for Production of Documents to Plaintiff 24 | |Robert O’Brien dated March 12, 2021. 25 12. LVMPD’s First Set of Request for Production of Documents to Plaintiff 26 | |Emily Driscoll dated March 12, 2021. 27 13. LVMPD’s First Set of Request for Production of Documents to Plaintiff 28) | Alison Kenady dated March 12, 2021. 13 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 14. LVMPD’s First Set of Request for Production of Documents to Plaintiff 2 | |Tenisha Martin dated March 12, 2021. 3 15. LVMPD’s First Set of Request for Production of Documents to Plaintiff 4 Gabriela Molina dated March 12, 2021. 5 16. LVMPD Defendants’ First Supplement to Initial Disclosures of Witnesses 6 and Documents Pursuant to FRCP 26.1(a)(1) dated July 20, 2021. 17. LVMPD’s Answers to Plaintiff Lance Downes-Covington’s First Set □□ Interrogatories dated July 20, 2021. ° 18. LVMPD’s Responses to Plaintiffs’ First Set of Requests for Production of Documents dated July 20, 2021.

1 19. LVMPD’s Responses to Plaintiff Emily Driscoll’s First Set of

- 2B Interrogatories dated August 3, 2021. 5 14 20. LVMPD’s Supplemental Answers to Plaintiff Lance Downes-Covington’s 15 First Set of Interrogatories dated August 3, 2021. 16 21. LVMPD’s Supplemental Responses to Plaintiffs’ First Set of Requests for = 17 | | Production of Documents dated August 3, 2021. 18 22. LVMPD Defendants’ Second Supplement to Initial Disclosures of 19 | | Witnesses and Documents Pursuant to FRCP 26.1(a)(1) dated August 4, 2021. 20 23. LVMPD’s Supplemental Answers to Plaintiff Lance Downes-Covington’s 21 | |First Set of Interrogatories dated August 9, 2021. 22 24. LVMPD Defendants’ Third Supplement to Initial Disclosures of Witnesses 23) |and Documents Pursuant to FRCP 26. 1(a)(1) dated August 16, 2021. 24 25. LVMPD’s Responses to Plaintiff Tenisha Martin’s First Set of 25 Interrogatories dated August 16, 2021. 26 26. LVMPD’s Responses to Plaintiff Tenisha Martin’s Second Set of a Interrogatories dated August 16, 2021. 28

STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 27. LVMPD’s Responses to Plaintiffs’ Third Set of Requests for Production of 2 | |Documents dated August 16, 2021. 3 28. LVMPD’s Responses to Plaintiffs’ Second Set of Requests for Production 4] | of Documents dated August 30, 2021. 5 29. LVMPD’s Responses to Plaintiff Tenisha Martin’s Second Set of 6 Interrogatories dated August 30, 2021. 30. LVMPD Defendants’ Fourth Supplement to Initial Disclosures of Witnesses and Documents Pursuant to FRCP 26.1(a)(1) dated August 30, 2021. ° 31. LVMPD Defendants’ Privilege Log dated August 30, 2021. 32. LVMPD’s Amended Responses to Plaintiffs’ Third Set of Requests for

Production of Documents dated September 13, 2021.

- 2B 33. LVMPD’s Amended Responses to Plaintiffs’ Second Set of Requests for 5 14 Production of Documents dated September 13, 2021. 15 34. LVMPD’s Amended Responses to Plaintiff Tenisha Martin’s Second Set □□ 16 | | Interrogatories dated September 13, 2021. = 17 35. LVMPD’s Amended Responses to Plaintiff Emily Driscoll’s First Set of 18 | |Interrogatories dated September 13, 2021. 19 36. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Lance Downes- 20 | |Covington dated September 22, 2021. 21 37. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Soldadera Sanchez 22 | dated September 22, 2021. 23 38. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Robert O’ Brien dated 24 | | September 22, 2021. 2 39. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Emily Driscoll dated 26 September 22, 2021. 27 28 15 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 40. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Alison Kenady dated 2 | |September 22, 2021. 3 41. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Tenisha Martin dated 4 | | September 22, 2021. 5 42. Lt. McKenzie’s First Set of Interrogatories to Plaintiff Gabriela Molina 6 dated September 22, 2021. 43. LVMPD’s First Set of Requests for Admission to Plaintiff Lance Downes- Covington dated September 22, 2021. ° 44. LVMPD’s First Set of Requests for Admission to Plaintiff Soldadera Sanchez dated September 22, 2021.

1 45. LVMPD’s First Set of Requests for Admission to Plaintiff Robert O’Brien

- 2B dated September 22, 2021. Bs 14 46. LVMPD’s First Set of Requests for Admission to Plaintiff Emily Driscoll 15 dated September 22, 2021. 16 47. LVMPD’s First Set of Requests for Admission to Plaintiff Alison Kenady = 17 | |dated September 22, 2021. 18 48. LVMPD’s First Set of Requests for Admission to Plaintiff Tenisha Martin 19 | |dated September 22, 2021. 20 49. LVMPD’s First Set of Requests for Admission to Plaintiff Gabriela Molina 21 | |dated September 22, 2021. 22 50. LVMPD Defendants’ Fifth Supplement to Initial Disclosures of Witnesses 23) |and Documents Pursuant to FRCP 26. 1(a)(1) dated October 11, 2021. 24 51. LVMPD’s Responses to Plaintiffs’ Fourth Set of Requests for Production 25 of Documents dated October 18, 2021. 26 52. LVMPD’s Responses to Plaintiff Tenisha Martin’s Third Set of a Interrogatories dated October 18, 2021. 28 16 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 53. LVMPD’s Responses to Plaintiffs’ First Set of Requests Admission dated 2 | |October 20, 2021. 3 54. LVMPD’s Answers to Plaintiff Lance Downes-Covington’s Second Set □□ 4 Interrogatories dated May 5, 2022. 5 55. LVMPD’s Answers to Plaintiff Alison Kenady’s First Set of Interrogatories 6 dated May 5, 2022. 56. LVMPD’s Answers to Plaintiff Robert O’Brien’s First Set of Interrogatories dated May 5, 2022. ° 57. LVMPD’s Answers to Plaintiff Sol Sanchez’s First Set of Interrogatories dated May 5, 2022.

1 58. LVMPD’s Responses to Plaintiffs’ Fifth Set of Requests for Production of

- 2B Documents dated May 5, 2022. 5 14 59. LVMPD’s Answers to Plaintiff Emily Driscoll’s Second Set of 15 Interrogatories dated May 5, 2022. 16 60. LVMPD’s Answers to Plaintiff Gabriella Molina’s First Set of = 17 | |Interrogatories dated May 5, 2022. 18 61. LVMPD’s Responses to Plaintiffs’ Second Set of Requests for Admissions 19 | |dated May 5, 2022. 20 62. LVMPD’s Second Supplemental Answers to Plaintiff Lance Downes- 21 | |Covington’s First Set of Interrogatories dated June 24, 2022. 22 63. LVMPD’s First Supplemental Responses to Plaintiffs’ Second Set of 23 Requests for Production of Documents dated June 24, 2022. 24 64. LVMPD’s First Supplemental Answers to Plaintiff Tenisha Martin’s 25 Second Set of Interrogatories dated June 24, 2022. 26 65. LVMPD’s Second Supplemental Responses to Plaintiffs’ First Set of Requests for Production of Documents dated June 24, 2022.

17 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 66. Lt. Kurt McKenzie’s Answers to Soldadera Sanchez’s First Set of 2 | |Interrogatories dated August 8, 2022. 3 67. Lt. Kurt McKenzie’s Answers to Tenisha Martin’s First Set of 4 Interrogatories dated August 8, 2022. 5 68. Lt. Kurt McKenzie’s Responses to Plaintiffs’ First Set of Requests for 6 Production of Documents dated August 8, 2022. 69. Patricia Spencer’s Responses to Plaintiffs’ First Set of Requests for Production of Documents dated August 8, 2022. ° 70. Tabatha Dickson’s Responses to Plaintiffs’ First Set of Requests for Admissions dated August 8, 2022.

1 71. Tabatha Dickson’s Answers to Lance Downes-Covington’s First Set □□

- 2B Interrogatories dated August 8, 2022. 14 72. LVMPD’s Responses to Plaintiffs’ Third Set of Requests for Admissions 15 dated August 8, 2022. 16 73. LVMPD’s Answers to Lance Downes-Covington’s Third Set of 17 | |Interrogatories dated August 8, 2022. 18 74. LVMPD’s Answers to Soldadera Sanchez’s Second Set of Interrogatories 19 | |dated August 8, 2022. 20 75. Captain Dori Koren’s Responses to Plaintiffs’ First Set of Requests for 21 | |Production of Documents dated August 8, 2022. 22 76. Tabatha Dickson’s Responses to Plaintiffs’ First Set of Requests for 23 | | Production of Documents dated August 8, 2022. 24 77. LVMPD’s Answers to Robert O’Brien’s Second Set of Interrogatories 25 dated August 8, 2022. 26 78. LVMPD’s Answers to Tenisha Martin’s Fourth Set of Interrogatories dated a August 8, 2022. 28 18 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 79. LVMPD’s Responses to Plaintiffs’ Sixth Set of Requests for Production of 2 | |Documents dated August 8, 2022. 3 80. LVMPD’s Answers to Emily Driscoll’s Third Set of Interrogatories dated 4| | August 8, 2022. 5 81. LVMPD Defendants’ Sixth Supplemental FRCP 26.1 Disclosures dated 6 August 8, 2022. 82. LVMPD Defendants’ Seventh Supplemental FRCP 26.1 Disclosures dated 8 December 6, 2022. ° 83. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for Production — Set One, dated December 6, 2022.

84. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for

- 2B Admission — Set One, dated December 6, 2022. 5 2 14 85. Jordan Tumer’s Responses to Lance Downes-Covington’s Interrogatories — 15 Set One, dated December 6, 2022. 16 86. Jordan Turner’s Responses to Lance Downes-Covington’s Requests for 17 | |Admission — Set One, dated December 6, 2022. 18 87. Jordan Turner’s Responses to Gabriela Molina’s Requests for Production — 19 | |Set One, dated December 6, 2022. 20 88. Tabatha Dickson’s Reponses to Lance Downes Covington’s Requests for 21 | |Production — Set One, dated December 6, 2022. 22 89. Tabatha Dickson’s Responses to Lance Downes-Covington’s 23 Interrogatories — Set One, dated December 6, 2022. 24 90. Tabatha Dickson’s Responses to Lance Downes-Covington’s 25 Interrogatories — Set Two, dated December 6, 2022. 26 91. Tabatha Dickson’s Responses to Lance Downes-Covington’s Requests for a Admission — Set One, dated December 6, 2022. 28 19 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 92. Tabatha Dickson’s Responses to Lance Downes-Covington’s Requests for 2 | |Production — Set One, dated December 6, 2022. 3 93. Tabatha Dickson’s Responses to Gabriela Molina’s Interrogatories — Set 4 One, dated December 6, 2022. 5 94. Tabatha Dickson’s Responses to Gabriela Molina’s Requests for Admission )_ Set One, dated December 6, 2022. 95. Tabatha Dickson’s Responses to Gabriela Molina’s Interrogatories — Set 8 One, dated December 6, 2022. ° 96. Tabatha Dickson’s Responses to Gabriela Molina’s Requests for Production — Set One, dated December 6, 2022.

1 97. Tabatha Dickson’s Responses to Emily Driscolls’ Requests for Admission

- Blt Set One, dated December 6, 2022. 5 2 14 98. Tabatha Dickson’s Responses to Emily Driscolls’ Interrogatories — Set One, 15 dated December 6, 2022. 16 99. LVMPD’S Responses to Lance Downes Covington’s Requests for 17 | | Production — Set One, dated December 6, 2022. 18 100. LVMPD’S Responses to Lance Downes Covington’s Requests for 19 | | Admission — Set One, dated December 6, 2022. 20 101. LVMPD’S Responses to Lance Downes Covington’s Interrogatories — Set |Four, dated December 6, 2022. 22 102. LVMPD’s Responses to Emily Driscolls’ Interrogatories — Set One, dated 23 | | December 6, 2022. 24 103. LVMPD’s Responses to Emily Driscolls’ Interrogatories — Set Four, dated 25 December 6, 2022. 26 104. LVMPD’s Responses to Emily Driscolls’ Requests for Admission — Set a One, dated December 6, 2022. 28 20 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 105. LVMPD’s Responses to Emily Driscolls’ Requests for Production — Set 2 | |One, dated December 6, 2022. 3 106. LVMPD’s Responses to Gabriela Molina’s Interrogatories — Set Two, dated 4 December 6, 2022. 5 107. LVMPD’s Responses to Gabriela Molina’s Requests for Production— Set 6 One, dated December 6, 2022. 108. LVMPD’s Responses to Gabriela Molina’s Requests for Admission — Set 8 One, dated December 6, 2022. ° 109. LVMPD Defendants’ Eighth Supplemental FRCP 26.1 Disclosures dated December 16, 2022.

1 110. LVMPD’S Responses to Tenisha Martin’s Requests for Admission — Set

- 2B One, dated December 19, 2022. 14 111. LVMPD’S Responses to Soldadera Sanchez’s Requests for Admission — 15 Set One, dated December 19, 2022. 16 112. LVMPD’S Responses to Robert O’Brien’s Requests for Admission — Set 17 | |One, dated December 19, 2022. 18 113. LVMPD’S Responses to Alison Kenady’s Requests for Admission — Set 19 | |One, dated December 19, 2022. 20 114. LVMPD’S Responses to Robert O’Brien’s Interrogatories — Set One, dated |December 19, 2022. 22 115. LVMPD’S Responses to Alison Kenady’s Requests for Production — Set 23 One, dated December 20, 2022. 24 116. LVMPD’S Responses to Robert O’Brien’s Requests for Production — Set 25 One, dated December 20, 2022. 26 117. LVMPD’s Responses to Soldadera Sanchez’ Requests for Production — Set a One, dated December 20, 2022. 28 2] STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 118. LVMPD’S Responses to Tenisha Martin’s Requests for Production — Set 2 | |One, dated December 20, 2022. 3 119. LVMPD’S Responses to Alison Kenady’s Interrogatories — Set Two, dated 4 January 4, 2023. 5 120. LVMPD’S Responses to Robert O’Brien’s Interrogatories — Set Three, 6 dated January 4, 2023. 121. LVMPD’s Ninth Supplemental Disclosure of Witnesses and Documents Pursuant to FRCP 26.1(a)(1), dated February 16, 2023. ° 122. LVMPD’s First Supplemental Answers to Plaintiff Robert O’Brien’s First Set of Interrogatories, dated February 16, 2023.

1 123. LVMPD’s First Supplemental Answers to Plaintiff Soldadera Sanchez’s

- 2B Second Set of Interrogatories, dated February 16, 2023. 5 14 124. LVMPD’s Third Supplemental Responses to Plaintiffs’ First Set of 15 Requests for Production of Documents, dated February 16, 2023. 16 125. LVMPD’s Second Supplemental Responses to Plaintiff's Second Set of 17 | |Requests for Production of Documents, dated February 16, 2023. 18 126. LVMPD’s First Supplemental Responses to Plaintiffs’ Sixth Set of 19 | |Requests for Production of Documents, dated February 16, 2023. 20 127. LVMPD’S Responses to Plaintiff Tenisha Martin’s Requests for Production 21 | of Documents — Set One [sic Set Two], dated February 16, 2023. 22 128. LVMPD’s Tenth Supplemental Disclosure of Witnesses and Documents Pursuant to FRCP 26. 1(a)(1), dated February 24, 2023. 24 C. DEPOSITIONS. 25 1. LVMPD Defendants deposed Plaintiff Alison Kenady on August 9, 2022.

2. LVMPD Defendants deposed Plaintiff Gabriela Molina on August 10, 28 2022. 22 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 3. LVMPD Defendants deposed Plaintiff Emily Driscoll on August 11, 2022. 2 4. LVMPD Defendants deposed Plaintiff Tenisha Martin on August 16, 2022. 3 5. LVMPD Defendants deposed Plaintiff Lance Downes-Covington on 4| | August 19, 2022. 5 6. LVMPD Defendants deposed Plaintiff Soldadera Sanchez on August 20, 6 2022. 7. Plaintiffs deposed Defendant Officer Jordan Tumer on October 18, 2022. 8. Plaintiffs deposed Defendant Officer Tabatha Dickson on October 24, 2022. ° Plaintiffs deposed Defendant Officer Evan Spoon on November 7, 2022. 9. Plaintiffs deposed Defendant Retired Captain Patricia Spencer on

November 15, 2022.

- 2B 10. Plaintiffs deposed Defendant Captain Dori Koren on November 22, 2022. 5 14 11. Plaintiffs deposed Defendant Lt. Kurt McKenzie on December 21, 2022. 15 12. The Parties are working to reschedule the deposition of Defendants’ 16 | |FRCP 30(b)(6) designee(s), which were scheduled for March 14, 2023. 17 13. LVMPD Defendants deposed Plaintiff Robert O’Brien on March 24, 18 | |2023. 19 Il. DISCOVERY THAT REMAINS TO BE COMPLETED. 20 The Parties are actively conducting discovery and have completed the majority of a1 the written discovery and depositions. However, the Parties are continuing to meet and confer on outstanding discovery issues, including Plaintiffs’ position that Defendants have not °3 produced all relevant and responsive BWC video footage. Plaintiffs are also continuing to review voluminous number of body-worn camera (BWC) footage videos, as are Defendants. The Parties’ primary remaining discovery tasks include: (1) Plaintiffs review of ° materials, including an additional 188GB of materials (on-going), produced as part of Defendants’ Ninth and Tenth Supplemental Disclosures, review of Defendants’ recent

23 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 | discovery responses; (2) resolution of meet and confer issues and motion practice if needed; 2 | |(3) Plaintiffs’ deposition of Defendant Las Vegas Metropolitan Police Department’s FRCP 3 30(b)(6) designee(s); (4) expert disclosures; (5) rebuttal reports; and (6) depositions of the 4 experts. 5 Hl. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY. ° This is the tenth request for an extension of discovery deadlines in this matter. The Parties request that the Discovery Plan and Scheduling Order deadlines be extended an ° additional sixty (60) days so that the Parties may complete the tasks above and efficiently ° manage expert disclosures. The Parties acknowledge that, pursuant to Local Rule 26-3, the Parties must

establish that good cause exists to extend the deadlines.

- B The Parties have been diligently conducting discovery and continue to conduct 14 discovery, but an extension is still needed to efficiently conclude discovery and manage the 15 case. Plaintiffs filed their Motion for Leave to File a Third Amended Complaint (ECF No. 16 126) to substitute the true names of three previously unnamed officers, add two new claims

3 7 (Wrongful Arrest and Malicious Prosecution), and add additional facts supporting Plaintiffs’ 18 claims, particularly regarding use of excessive force. The Court issued its Report and 19 Recommendation in response to Plaintiffs’ Motion for Leave to File a Third Amended 0 Complaint on April 20, 2023, recommending that Plaintiffs’ Motion be denied (ECF No. 1 144). Plaintiffs’ objections to the Court’s Report and Recommendation are due May 4, 2023. Additionally, Defendants recently supplemented a variety of discovery responses and 3 | |produced an additional 218 BWC footage videos. Given the number of BWC videos, 74 | Plaintiffs will need additional time to review. Further, Plaintiffs’ counsel is continuing to 25 | |meet and confer with Defendants’ counsel regarding the FRCP 30(b)(6) deposition topics. 26 | Plaintiffs also intend to bring a Motion for Sanctions regarding the failure to activate BWCs 27 | |and/or preserve BWC video footage. Meet and confer efforts are ongoing. 28 24 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 Likewise, the experts retained in this matter will also need to review the recent 2 | |discovery responses, BWC videos, and all deposition transcripts, including the March 24, 3 | 12023, deposition of Plaintiff Robert O’Brien and the FRCP 30(b)(6) designees currently lscheduled for in or about the end of May, after the current deadline for initial expert |disclosures. The Parties are working with their respective experts to prepare their expert 6 | Idisclosures. However, as noted, the Parties contend that it is more efficient to allow further 7 discovery to be completed before initial expert disclosures to minimize the need for 8 supplementation. ? Finally, the Parties together request this in good faith and to further the resolution 10 of this complicated case on the merits, and not for any purpose of delay. The Parties thus respectfully request an extension of time to extend the discovery in this matter to enable to them to conduct necessary discovery in this matter and so that this 13 matter is fairly resolved on the merits. “Good cause to extend a discovery deadline exists ‘if it cannot reasonably be met despite the diligence of the party seeking the extension.’” Derosa v. Blood Sys., Inc., No. 2:13-cv-0137-JCM-NJK, 2013 U.S. Dist. LEXIS 108235, 2013 WL 16 3975764, at 1 (D. Nev. Aug. 1, 2013) (quoting Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)); see also Fed. R. Civ. P. 1 (providing that the Rules of Civil 8 Procedure “should be construed, administered, and employed by the court and the Parties to ” secure the just, speedy, and inexpensive determination of every action and proceeding”). As “0 the procedural history of this case illustrates, the Parties have been diligent in litigating this matter. Additionally, counsel for the Parties in this matter are litigating several other 2 unrelated matters (including against each other) which have competing demands. While °° competing demands of litigation are merely one of many reasons for the instant request, it should be noted that the other litigation between the same counsel involving similar issues can only benefit from the completion of discovery in this matter so that in other litigation, similar requests can be expedited and can further the resolution of those matters and the interests of justice. Indeed, counsel for the Parties continue to engage in settlement 25 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

1 | |discussions regarding this and the other matters they are litigating that stem from the BLM 2 protests. 3 Thus, the standards to extend all deadlines, including the expert deadlines, is 4 | | satisfied here. 5 Based on the foregoing stipulation and proposed deadlines plan, the Parties thus 6 respectfully request an extension of time to extend the discovery in this matter to enable to 7| |them to conduct necessary discovery in this matter and so that this matter is fairly resolved 8 | Jon the merits. ii Wy) ay) yy □□□ ry) rr yyy 2252 16 iff = 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 26 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST

IV. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DEADLINES 2 The Parties propose to add sixty (60) days to all current deadlines: 3 Current Deadline Proposed New Deadline 4 Amend Pleadings and June 14, 2022 Past/Unchanged 5 Add Parties 6 Initial Expert Disclosures May 8, 2023 July 7, 2023 Rebuttal Expert June 5, 2023 August 4, 2023 7 || | Disclosures g Discovery Cut-Off July 3, 2023 September 1, 2023 9 August 24, 2023 October 23, 2023 Pretrial Order September 5, 2023 November 6, 2023! 10 (If dispositive motions are filed, the deadline for shall be suspended until thirty (30) days 1] after the decision of the dispositive motions D or further order of the Court.)

13 Dated this 5" day of May, 2023. Dated this 5" day of May, 2023. 3 14 MCLETCHIE LAW MARQUIS AURBACH By: /s/ Pieter M. O'Leary By: /s/ Jackie V. Nichols 15 Margaret A. McLetchie, Esq. Craig R. Anderson, Esq. 3 5 16 Nevada Bar No. 10931 Nevada Bar No. 6882 Pieter M. O’Leary, Esq. Jackie V. Nichols, Esq. 17 Nevada Bar No. 15297 Nevada Bar No. 14246 Leo S. Wolpert, Esq. 10001 Park Run Drive 18 Nevada Bar No. 12658 Las Vegas, Nevada 89145 19 602 South 10th Street Attorneys for Defendants Las Vegas Las Vegas, Nevada 89101 Metropolitan Police Department, 20 Attorneys for Plaintiffs Lieutenant Kurt McKenzie, Officer Tabatha Dickson, Captain Patricia 2] Spencer and Captain Dori Koren 22 23 ORDER 24 IT IS SO ORDERED. OQ) 25 CO? xX DATED: 5/8/2023 SAW! 2 6 UNITED STATES MAGISTRATE JUDGE 27 8 gg 60 days from September 5, 2023, 1s Saturday, November 4, 2023. 27 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER DEADLINES — TENTH REQUEST