PAUL S. PADDA, ESQ. (NV Bar #10417) 1 Email: psp@paulpaddalaw.com 2 PAUL PADDA LAW, PLLC 4560 South Decatur Boulevard, Suite 300 3 Las Vegas, Nevada 89103 Tele: (702) 366-1888 4 Fax: (702) 366-1940 5 -and- ANTONIO M. ROMANUCCI, ESQ. (Admitted PHV) 6 Email: aromanucci@rblaw.net JOSHUA M. LEVIN, ESQ. (Admitted PHV) 7 Email: jlevin@rblaw.net 8 COLTON JOHNSON TAYLOR, ESQ. (Admitted PHV) Email: cjohnson@rblaw.net 9 ROMANUCCI & BLANDIN, LLC 10 321 North Clark Street, Suite 900 Chicago, Illinois 60654 11 Tele: (312) 458-1000 12 Attorneys for Plaintiff 13 UNITED STATES DISTRICT COURT 14 DISTRICT OF NEVADA 15 16 KRISTINA KERLUS, an individual; 17 Case No. 2:24-cv-02352-APG-DJA Plaintiff, 18 vs. 19 DR. JENNIFER CORNEAL, in her 20 individual capacity; ANGIE SANTOS, in her STIPULATION TO EXTEND individual capacity; COUNTY OF CLARK, DISCOVERY 21 a municipal corporation; LAS VEGAS (Second Request) METROPOLITAN POLICE 22 DEPARTMENT an independent political 23 subdivision; jointly and severally, 24 Defendants. 25 26 27 28 1 Pursuant to LR 26-4 and LR IA 6-1, Plaintiff Kristina Kerlus and Defendants Dr. Jennifer 2 Corneal, County of Clark, Angie Santos, and the Las Vegas Metropolitan Police Department 3 (collectively, “Defendants”), hereby request that the Court enter an order extending the unexpired 4 discovery deadlines in this matter for 120 days. The parties can demonstrate good cause for the 5 extension, as explained below, and the requested extension is being requested within twenty-one 6 (21)days of any deadline. In support of this request, the parties state as follows: 7 A. Statement of Completed Discovery 8 To date, all parties have exchanged their initial Rule 26 disclosures and have produced a 9 total of roughly 1,000 documents. Additionally, the parties have conducted extensive written 10 discovery, as described below: 11 Defendants Dr. Jennifer Corneal and the County of Clark (“the County Defendants”) and 12 Defendants Angie Santos and Las Vegas Metropolitan Police Department (“LVMPD 13 Defendants”) have propounded Requests for Production, Interrogatories, and Requests for 14 Admission to Plaintiff. Specifically, the County Defendants propounded 46 Requests for 15 Production, 15 Interrogatories, 41 Requests for Admission to Plaintiff. The LVMPD 16 Defendants have propounded 50 Requests for Production, 25 Interrogatories, and 111 17 Requests for Admission to Plaintiff. 18 Plaintiff has provided written responses to all discovery requests propounded to her. 19 Additionally, Plaintiff has propounded 57 Requests for Production and 16 Interrogatories 20 to the County of Clark. Further, Plaintiff has propounded 50 Requests for Production and 21 16 Interrogatories to Defendant LVMPD. Finally, Plaintiff has propounded 41 Requests 22 for Production to Defendant Angie Santos and 37 Requests for Production to Defendant 23 Jennifer Corneal. The parties are still in the process of exchanging complete document 24 production in response to the propounded requests. 25 B. Discovery that Remains to be Completed 26 The parties must complete written fact discovery, including completing document 27 production in response to the propounded requests. As to oral discovery, the parties anticipate 28 1 most depositions being scheduled for a period after document production (in response to the 2 requests propounded to date) is substantially complete. The parties anticipate propounding 3 additional discovery requests as depositions proceed and after review of the document 4 productions made in response to the parties’ first sets of discovery. This is particularly the case 5 for Plaintiff, whose Monell claims involve proving unofficial customs within Defendants County 6 of Clark and LVMPD, which requires substantial written discovery spanning multiple years. 7 Additionally, expert discovery remains to be done. The parties will also serve any necessary third- 8 party subpoenas. 9 C. Reasons Why Remaining Discovery Has Not Been Completed. 10 A standard of “good cause” governs this request because the to-be-extend deadlines have 11 not yet expired. D. Nev. Local Rule 26-3. Good cause “primarily considers the diligence” of the 12 parties seeking the extension. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 13 1992) (explaining that “[t]he district court may modify the pretrial schedule if it cannot reasonably 14 be met despite the diligence of the party seeking the extension.”) (internal quotations omitted). 15 “Motions for extension must include a statement specifying the discovery completed, a 16 description of discovery remaining, the reasons why the deadline was not satisfied, and a 17 proposed schedule for completing remaining discovery.” Hampton v. Nevada, No. 2:20-cv- 18 00578-APG-DJA, 2021 WL 3573640, at *2 (D. Nev. July 29, 2021). 19 Plaintiff filed a Second Amended Complaint (“SAC”) on October 14, 2025. [ECF No. 20 68]. In response, Defendants filed Motions to Dismiss as their responsive pleadings. [ECF Nos. 21 74 and 75]. Briefing on the pending Motions was recently completed on January 13, 2026. The 22 Motions are now fully briefed and pending a ruling from the Court. An extension is necessary to 23 allow the Court time to consider the Motions. Moreover, Plaintiff does not yet have the 24 Defendants’ answers or affirmative defenses, which Plaintiff is entitled to take discovery on. 25 The current discovery plan will not leave the parties enough time to complete the 26 extensive fact discovery, particularly document production, needed for this multi-party case 27 involving complex Monell claims. Given the large amount of document production that remains 28 1 to be done, the parties have determined that a 120-day extension of the discovery deadlines is 2 necessary to complete fact and expert discovery. This extension will provide sufficient time for 3 the parties to complete document productions for the discovery propounded to date, review of 4 those productions and identification of individuals to be deposed, completion of depositions, and 5 issuance of any remaining written discovery requests. The extension will also provide sufficient 6 time for the parties to complete expert discovery. 7 D. PROPOSED EXTENDED DEADLINES 8 9 The parties respectfully request this Court enter an order as follows: 10 Deadline Current Date Proposed New Date 11 Discovery Cut Off May 27, 2026 September 24, 2026 12 Disclosure of Experts March 30, 2026 July 27, 2026 13 14 Disclosure of Rebuttal Experts April 29, 2026 August 26, 2026 15 Dispositive Motion Deadline: June 26, 2026 October 26, 2026 16 Pre-Trial Order July 27, 2026 November 25, 2026 17 18 (1) Motions in Limine/Daubert Motions. 19 20 Under LR 16-3(b), any motions in limine, including Daubert motions, shall be filed and 21 served 30 days prior to the commencement of Trial. Oppositions shall be filed and served 14 22 days thereafter. Reply briefs will be allowed only with leave of the Court. 23 (2) Pretrial Order. 24 Pursuant to LR 26(1)(e)(5), the Joint Pretrial Order shall be filed with this Court no later 25 26 than thirty days after the date set for filing dispositive motions, unless dispositive motions are 27 filed, in which case the date for filing the Joint Pretrial Order shall be suspended until 30 days 28 after the decision on the dispositive motions or further order of this Court. The disclosures 1 2 required by FRCP 26(a)(3) and any objections shall be included in the final pretrial order. 3 (3) Extensions or Modification of the Discovery Plan and Scheduling Order.
Free access — add to your briefcase to read the full text and ask questions with AI
PAUL S. PADDA, ESQ. (NV Bar #10417) 1 Email: psp@paulpaddalaw.com 2 PAUL PADDA LAW, PLLC 4560 South Decatur Boulevard, Suite 300 3 Las Vegas, Nevada 89103 Tele: (702) 366-1888 4 Fax: (702) 366-1940 5 -and- ANTONIO M. ROMANUCCI, ESQ. (Admitted PHV) 6 Email: aromanucci@rblaw.net JOSHUA M. LEVIN, ESQ. (Admitted PHV) 7 Email: jlevin@rblaw.net 8 COLTON JOHNSON TAYLOR, ESQ. (Admitted PHV) Email: cjohnson@rblaw.net 9 ROMANUCCI & BLANDIN, LLC 10 321 North Clark Street, Suite 900 Chicago, Illinois 60654 11 Tele: (312) 458-1000 12 Attorneys for Plaintiff 13 UNITED STATES DISTRICT COURT 14 DISTRICT OF NEVADA 15 16 KRISTINA KERLUS, an individual; 17 Case No. 2:24-cv-02352-APG-DJA Plaintiff, 18 vs. 19 DR. JENNIFER CORNEAL, in her 20 individual capacity; ANGIE SANTOS, in her STIPULATION TO EXTEND individual capacity; COUNTY OF CLARK, DISCOVERY 21 a municipal corporation; LAS VEGAS (Second Request) METROPOLITAN POLICE 22 DEPARTMENT an independent political 23 subdivision; jointly and severally, 24 Defendants. 25 26 27 28 1 Pursuant to LR 26-4 and LR IA 6-1, Plaintiff Kristina Kerlus and Defendants Dr. Jennifer 2 Corneal, County of Clark, Angie Santos, and the Las Vegas Metropolitan Police Department 3 (collectively, “Defendants”), hereby request that the Court enter an order extending the unexpired 4 discovery deadlines in this matter for 120 days. The parties can demonstrate good cause for the 5 extension, as explained below, and the requested extension is being requested within twenty-one 6 (21)days of any deadline. In support of this request, the parties state as follows: 7 A. Statement of Completed Discovery 8 To date, all parties have exchanged their initial Rule 26 disclosures and have produced a 9 total of roughly 1,000 documents. Additionally, the parties have conducted extensive written 10 discovery, as described below: 11 Defendants Dr. Jennifer Corneal and the County of Clark (“the County Defendants”) and 12 Defendants Angie Santos and Las Vegas Metropolitan Police Department (“LVMPD 13 Defendants”) have propounded Requests for Production, Interrogatories, and Requests for 14 Admission to Plaintiff. Specifically, the County Defendants propounded 46 Requests for 15 Production, 15 Interrogatories, 41 Requests for Admission to Plaintiff. The LVMPD 16 Defendants have propounded 50 Requests for Production, 25 Interrogatories, and 111 17 Requests for Admission to Plaintiff. 18 Plaintiff has provided written responses to all discovery requests propounded to her. 19 Additionally, Plaintiff has propounded 57 Requests for Production and 16 Interrogatories 20 to the County of Clark. Further, Plaintiff has propounded 50 Requests for Production and 21 16 Interrogatories to Defendant LVMPD. Finally, Plaintiff has propounded 41 Requests 22 for Production to Defendant Angie Santos and 37 Requests for Production to Defendant 23 Jennifer Corneal. The parties are still in the process of exchanging complete document 24 production in response to the propounded requests. 25 B. Discovery that Remains to be Completed 26 The parties must complete written fact discovery, including completing document 27 production in response to the propounded requests. As to oral discovery, the parties anticipate 28 1 most depositions being scheduled for a period after document production (in response to the 2 requests propounded to date) is substantially complete. The parties anticipate propounding 3 additional discovery requests as depositions proceed and after review of the document 4 productions made in response to the parties’ first sets of discovery. This is particularly the case 5 for Plaintiff, whose Monell claims involve proving unofficial customs within Defendants County 6 of Clark and LVMPD, which requires substantial written discovery spanning multiple years. 7 Additionally, expert discovery remains to be done. The parties will also serve any necessary third- 8 party subpoenas. 9 C. Reasons Why Remaining Discovery Has Not Been Completed. 10 A standard of “good cause” governs this request because the to-be-extend deadlines have 11 not yet expired. D. Nev. Local Rule 26-3. Good cause “primarily considers the diligence” of the 12 parties seeking the extension. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 13 1992) (explaining that “[t]he district court may modify the pretrial schedule if it cannot reasonably 14 be met despite the diligence of the party seeking the extension.”) (internal quotations omitted). 15 “Motions for extension must include a statement specifying the discovery completed, a 16 description of discovery remaining, the reasons why the deadline was not satisfied, and a 17 proposed schedule for completing remaining discovery.” Hampton v. Nevada, No. 2:20-cv- 18 00578-APG-DJA, 2021 WL 3573640, at *2 (D. Nev. July 29, 2021). 19 Plaintiff filed a Second Amended Complaint (“SAC”) on October 14, 2025. [ECF No. 20 68]. In response, Defendants filed Motions to Dismiss as their responsive pleadings. [ECF Nos. 21 74 and 75]. Briefing on the pending Motions was recently completed on January 13, 2026. The 22 Motions are now fully briefed and pending a ruling from the Court. An extension is necessary to 23 allow the Court time to consider the Motions. Moreover, Plaintiff does not yet have the 24 Defendants’ answers or affirmative defenses, which Plaintiff is entitled to take discovery on. 25 The current discovery plan will not leave the parties enough time to complete the 26 extensive fact discovery, particularly document production, needed for this multi-party case 27 involving complex Monell claims. Given the large amount of document production that remains 28 1 to be done, the parties have determined that a 120-day extension of the discovery deadlines is 2 necessary to complete fact and expert discovery. This extension will provide sufficient time for 3 the parties to complete document productions for the discovery propounded to date, review of 4 those productions and identification of individuals to be deposed, completion of depositions, and 5 issuance of any remaining written discovery requests. The extension will also provide sufficient 6 time for the parties to complete expert discovery. 7 D. PROPOSED EXTENDED DEADLINES 8 9 The parties respectfully request this Court enter an order as follows: 10 Deadline Current Date Proposed New Date 11 Discovery Cut Off May 27, 2026 September 24, 2026 12 Disclosure of Experts March 30, 2026 July 27, 2026 13 14 Disclosure of Rebuttal Experts April 29, 2026 August 26, 2026 15 Dispositive Motion Deadline: June 26, 2026 October 26, 2026 16 Pre-Trial Order July 27, 2026 November 25, 2026 17 18 (1) Motions in Limine/Daubert Motions. 19 20 Under LR 16-3(b), any motions in limine, including Daubert motions, shall be filed and 21 served 30 days prior to the commencement of Trial. Oppositions shall be filed and served 14 22 days thereafter. Reply briefs will be allowed only with leave of the Court. 23 (2) Pretrial Order. 24 Pursuant to LR 26(1)(e)(5), the Joint Pretrial Order shall be filed with this Court no later 25 26 than thirty days after the date set for filing dispositive motions, unless dispositive motions are 27 filed, in which case the date for filing the Joint Pretrial Order shall be suspended until 30 days 28 after the decision on the dispositive motions or further order of this Court. The disclosures 1 2 required by FRCP 26(a)(3) and any objections shall be included in the final pretrial order. 3 (3) Extensions or Modification of the Discovery Plan and Scheduling Order. 4 In accordance with LR 26-3, applications to extend any date set by the discovery plan, 5 scheduling order, or other order must, in addition to satisfying the requirements of LR 6-1, be 6 supported by a showing of good cause for the extension. All motions or stipulations to extend a 7 8 deadline set forth in a discovery plan shall be received by the Court not later than 21 days before 9 the expiration of the subject deadline. A request made after the expiration of the subject deadline 10 shall not be granted unless the movant demonstrates that the failure to set was the result of 11 excusable neglect. Any motion or stipulation to extend a deadline or to reopen discovery shall 12 13 include: 14 (a) A statement specifying the discovery completed; 15 (b) A specific description of the discovery that remains to be completed; 16 (c) The reasons why the deadline was not satisfied or the remaining discovery was not 17 completed within the time limits set by the discovery plan; and 18 19 (d) A proposed scheduled for completing all discovery. 20 The parties submit that good cause exists for an extension of the discovery deadlines for 21 the reasons stated above. The parties intend to conduct discovery in an expeditious manner. This 22 delay will not impede this matter and, in fact, will allow the Court time to rule on the pending 23 Motions to Dismiss and the parties to continue to conduct discovery in an effective and efficient 24 manner. No Trial has been set and dispositive motions have not been filed. 25 Dated this ____ day of February, 2026. 26 27 28 1 By: /s/ Colton M. Johnson Taylor By: /s/ Lyssa S. Anderson ANTONIO M. ROMANUCCI (PHV) LYSSA S. ANDERSON 2 || JOSHUA M. LEVIN (PHV) KRISTOPHER J. KALKOWSKI COLTON M. JOHNSON TAYLOR (PHV) TRAVIS C. STUDDARD 3 || ROMANUCCI & BLANDIN KAEMPFER CROWELL 4 321 North Clark Street, Suite 900 1980 Festival Plaza Drive Suite 650 Chicago, Illinois 606546385 Las Vegas, NV 89135 5 || G12) 458-1000 landerson@kenvlaw.com aromanucci@rblaw.net kkalkowski@kcnvlaw.com 6 jlevin@rblaw.net tstuddard@kenvlaw.com 7 || cjohnson@rblaw.net Attorneys for Defendant A. Santos and 8 Las Vegas Metropolitan Police g || By: /s/ Paul S. Padda Department PAUL S. PADDA, ESQ. 10 |} PAUL PADDA LAW, PLLC Nevada Bar #10417 By: /s/ Robert W. Freeman 11 || 4560 South Decatur Blvd., Ste. 300 ROBERT W. FREEMAN 22 Las Vegas, NV 89103 ETHAN M. FREEMAN |? ||psp.paulpaddalaw.com LEWIS, BRISBOIS, 33 BISGAARD & Attorneys for Plaintiff Kristina Kerlus SMITH, LLP 14 6385 S. Rainbow Blvd, Suite 600 Z 1 robert.freeman@lewisbrisbois.com x 5 matt.freeman@lewisbrisbois.com 3 PS 16 = 8 = Attorneys for Dr. Jennifer Corneal and = 17 County of Clark 19 20 21 22 ORDER 23 IT IS SO ORDERED. 24 Dated this 4th day of February, 2026.
26 UNITED STATESIMAGISTRATE JUDGE 27 28