Sandoval v. State of Nevada ex rel. Nevada Department of Corrections

Opinion

Attorney General 2 RUDOLF M. D’SILVA (Bar No. 16227) Deputy Attorney General 3 State of Nevada Office of the Attorney General 4 1 State of Nevada Way, Suite 100 Las Vegas, Nevada 89119 5 (702) 486-3375 (phone) (702) 486-3768 (fax) 6 Email: rdsilva@ag.nv.gov

7 Attorneys for Interest Party The Nevada Department of Corrections 8

9 UNITED STATES DISTRICT COURT

10 DISTRICT OF NEVADA

11 LUIS SANDOVAL, Case No. 2:25-cv-00500-MMD-NJK

12 Plaintiff, STIPULATION AND ORDER SETTING DEADLINES FOR 13 v. ACCEPTANCE OF SERVICE AND RESPONSES TO COMPLAINT 14 STATE OF NEVADA EX REL. NEVADA [ECF NO.1] DEPARTMENT OF CORRECTIONS, et al., 15 Defendants. 16 17 Plaintiff Luis Sandoval, by and through counsel, Andre M. Lagomarsino, Esq. and 18 Cristina P. Valentine, Esq, and Interested Party Nevada Department of Corrections 19 (NDOC), by and through counsel, Aaron D. Ford, Nevada Attorney General, Randall 20 Gilmer, Chief Deputy Attorney General, and Rudolf M. D’Silva, Deputy Attorney General, 21 of the State of Nevada, Office of the Attorney General, and Interested Party Nevada 22 Division of Forestry, by and through counsel, Aaron D. Ford, Nevada Attorney General, 23 and Nicole Ting, Deputy Attorney General, respectfully submit the following Stipulation 24 and Order to setting deadlines for when the Office of the Attorney General (OAG) will 25 accept service for the Defendants they will be representing in this lawsuit, and when 26 Defendants will file a response to Plaintiff’s Complaint once service has been accepted. 27 /// 28 /// 2 Plaintiff Luis Sandoval (Sandoval) brought causes of action against several 3 Defendants under Section 1983, and for violation of the United States Constitution, the 4 Nevada Constitution, the Americans with Disabilities Act, and Section 504 of the 5 Rehabilitation Act. ECF No. 1 at 2:1-5. Sandoval has brought suit against state government 6 entities the Nevada Department of Corrections (NDOC) and the Nevada Division of 7 Forestry (NDF). Id. at 4:2-11. Sandoval has also filed suit against the following individuals 8 who are employed by either the NDOC or the NDF: Jermey Bean, Ronald Oliver, Kacey 9 KC, Kimberly McCoy, Gillian Lambey, Mark Galven Martinez, Patricio Cordero, Edgar 10 Desantiago, Kenneth Williams, Justin McRoberts, Elbeth Albana, Mirit Avram, Symour 11 Omandac, and several Doe Defendants. Id. at 4:12-13:19. 12 II. LEGAL STANDAND 13 A stipulation is an agreement between the parties as to a fact of the case, and, as 14 such, it is evidence introduced by both of the parties. U.S. v. Hawkins, 215 F.3d 858, 860 15 (8th Cir. 2000). Stipulations relating to proceedings before the court… must be in writing 16 and signed by all parties who have appeared or their attorneys. LR 7-1(a). No stipulation 17 relating to proceedings before the court … are effective until approved by the court. 18 LR 7-1(b). 19 III. DEADLINES 20 The Office of the Attorney General’s (OAG) respective divisions, which represent the 21 NDOC and NDF, agree to file a Notices of Acceptance of Service by May 23, 2025, notifying 22 this Court and the Parties in this lawsuit which defendants the OAG will be accepting 23 service on behalf of. Upon filing the Notice of Acceptance of Service, Defendants will file an 24 answer or other response within thirty (30) days from the date service is accepted. 25 /// 26 /// 27 /// 28 1 Additionally, the Parties agree that Plaintiff will be allowed to immediately engage 2 ||in expedited discovery for the limited purpose of discovering the identities of defendants 3 |/identified by fictitious names in Plaintiff's Complaint. 4 || DATED this 6th day of May, 2025. DATED this 6th day of May, 2025. 5 AARON D. FORD 6 Attorney General

7 || By: /s/ Andre M. Lagomarsino By: /s/ Rudolf M. D’Silva ANDRE M. LAGOMARSINO, ESQ (#6711) RANDALL GILMER @14001) 8 || CRISTINA P. VALENTINE, ESQ (#16440) RUDOLF M. D’SILVA @16227) Attorneys for Plaintiff Deputy Attorney Generals 9 Attorneys for NDOC Defendants 10 || DATED this 6th day of May, 2025. 11 By:_/s/ Nicole Ting 12 NICOLE TING, ESQ @12289) Deputy Attorney General 13 || Attorney for NDF Defendants 14 IT IS SO ORDERED:

16 UNITED STATES MAGISTRATE JUDGE 17 DATED: May 7, 2025 18 19 20 21 22 23 24 25 26 27 28