Opinion
2:21-cv-01346
10-07-2022
Patrick C. McDonnell, Esq. Nevada Bar No. 13188 MICHAELSON & ASSOCIATES, LTD. Antonio M. Romanucci (Pro Hac Vice) Bhavani Raveendran (Pro Hac Vice) ROMANUCCI & BLANDIN, LLC Benjamin J. Crump (Pro Hac Vice) CRUMP LAW Attorneys for Plaintiffs MARQUIS AURBACH COFFING Craig R. Anderson Nevada Bar No. 6882 Attorney for Defendants
Patrick C. McDonnell, Esq.
Nevada Bar No. 13188
MICHAELSON & ASSOCIATES, LTD.
Antonio M. Romanucci (Pro Hac Vice)
Bhavani Raveendran (Pro Hac Vice)
ROMANUCCI & BLANDIN, LLC
Benjamin J. Crump (Pro Hac Vice)
CRUMP LAW
Attorneys for Plaintiffs
MARQUIS AURBACH COFFING
Craig R. Anderson
Nevada Bar No. 6882
Attorney for Defendants
STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF'S " 26(A)(2) EXPERT DISCLOSURES
Pursuant to Rule 26(a)(2) of the Federal Rules of Civil Procedure and Local Rule 26-3, Plaintiffs, Marcia Wells, Teena Acree, Tina Lewis-Stevenson, Gwendolyn Lewis, Robyn Williams, and Dewain Lewis (hereinafter, the “Plaintiffs”) and Defendants Las Vegas Metropolitan Police Department, Officer Patrick Campbell, Officer Benjamin Vasquez, Officer Alexander Gonzalez, and Officer Rocky Roman (hereinafter, the “Defendants”), by and through their respective counsel of record, hereby stipulate and agree to extend the time for Plaintiff's to complete their FRCP 26(a)(2) disclosures. This Stipulation is being entered in good faith and not for purposes of delay.
I. STATUS OF DISCOVERY.
The parties have completed all but two depositions and have been working together to meet all pending deadlines.
II. DISCOVERY THAT REMAINS TO BE COMPLETED.
The parties have two controlled fact witness depositions and expert disclosures to complete by the discovery deadline of December 10, 2022 and are on track to do so.
III. SPECIFIC DESCRIPTION OF WHY EXTENSION IS NECESSARY.
Pursuant to Local Rule 26-3, the Parties submit that good causes exist for the extension requested. The Parties have been diligently conducting discovery and continue to conduct discovery. However, additional time is needed for Plaintiff's expert disclosure, currently due October 10, 2022, because lead Plaintiff's counsel has trials set for October 12, 2022 and October 24, 2022 that have had unexpected complications. Namely, that lead Plaintiff's Counsel's office has had another two trials that have gone forward in the month of October. In addition, Plaintiff's expert has been unexpectedly required to testify in three different trials over the course of the last few weeks. These matters make it unlikely Plaintiffs' counsel will be able to complete expert disclosures by the previously agreed upon October 10, 2022 date.
IV. PROPOSED SCHEDULE FOR COMPLETING REMAINING DEADLINES
Current Deadline
Proposed New Deadline
Plaintiffs Initial Expert Disclosures
October 10, 2022
October 28, 2022
Based on the foregoing stipulation and proposed deadlines plan, the Parties request that the Discovery Plan and Scheduling Order deadlines be extended as stated herein, so that the parties may disclose experts.
IT IS SO STIPULATED AND AGREED.
IT IS SO ORDERED.