STATUS REPORT

BRENDA WEKSLER, Magistrate Judge.

Plaintiff Joshua Crittendon, by and through his counsel of record, Seth M. Strickland, Defendants Las Vegas Metropolitan Police Department, Rogers, Sanchez, Torres, Brown, Patimeteeporn, Senior, Trost, Verduzco, Binko, Reynolds, Johnson and Williams (the "LVMPD Defendants") by and through their counsel of record, Nick D. Crosby and Jackie Nichols of Marquis Aurbach Coffing, and Defendant Larry Williamson, M.D., by and through his attorneys of record, S. Brent Vogel and Katherine J. Gordon of Lewis Brisbois Bisgaard & Smith LLP, hereby submit their Status Report with updated requested discovery dates.

On December 23, 2019, counsel for the parties participated in a conference to discuss whether discovery should be extended, the length of an extension, and corresponding new discovery deadlines. As a result of the conference, counsel agreed to the information set forth below. The Status Report is separated into two portions according to Plaintiff's claims; i.e. (1) the "LVMPD Claims", and (2) the "Medical Claims", as bifurcated by the Honorable Richard F. Boulware in ECF No. 136.

I.

THE LVMPD CLAIMS

A. Discovery

Discovery is closed. Plaintiff reserves the right to file a request with the Court to reopen discovery.

B. Disclosures

Counsel for Plaintiff was recently appointed. Counsel for the LVMPD Defendants has provided Plaintiff's counsel their prior disclosures submitted pursuant to Fed. R. Civ. P. 26. Counsel for the LVMPD Defendants will also forward Plaintiff counsel copies of all written discovery exchanged between the LVMPD Defendants and Plaintiff.

C. Dispositive Motions

The LVMPD Defendants previously filed a Motion for Summary Judgment [ECF No. 150] which was denied by the Court without prejudice to allow time for counsel to be appointed for Plaintiff. In order to provide Plaintiff counsel time to review the prior disclosures and written discovery, a new due date for dispositive motions is provided, to expire on Thursday, April 2, 2020 (which is 90 days from the date of this Status Report and stipulation).

II.

THE MEDICAL CLAIMS

A. Discovery

This matter, including discovery, remains stayed until Plaintiff files his anticipated second amended complaint which, according to the Court, is to contain "an affidavit as it relates to Defendant Williamson and the medical malpractice claim previously raised" pursuant to N.R.S. 41A.071. [ECF No. 136].

The parties agree that Plaintiff will have an additional 30 days, from the date of this Status Report and stipulation, to file a second amended complaint. The new due date for a second amended complaint is Monday, February 3, 2020.

The parties further agree to a new discovery deadline of 180 days after Plaintiff files a second amended complaint. Counsel for Plaintiff and Dr. Williamson agree to file an Updated Status Report and Proposed Discovery Plan Regarding the Medical Claims following the filing of Plaintiff's second amended complaint which will provide an exact discovery cut-off date.

B. Disclosures

Counsel for Plaintiff was recently appointed. Counsel for Dr. Williamson will forward Plaintiff counsel his prior disclosures submitted pursuant to Fed. R. Civ. P. 26. Counsel for Dr. Williamson will also forward Plaintiff counsel copies of all written discovery exchanged between Dr. Williamson and Plaintiff.

C. Experts

Pursuant to Fed. R. Civ. P. 26(a)(2) and L.R. 26-1(b)(3), the parties agree the due date for initial expert disclosures shall be 60 days before the discovery cut-off date and that rebuttal expert disclosures shall be made 30 days after the initial disclosure of experts. Counsel for Plaintiff and Dr. Williamson agree to file an Updated Status Report and Proposed Discovery Plan Regarding the Medical Claims following the filing of Plaintiff's second amended complaint which will provide specific due dates for initial and rebuttal expert disclosures.

D. Dispositive Motions

The deadline for filing dispositive motions will be 30 days after the discovery cut-off date pursuant to L.R. 26-1(b)(4). Counsel for Plaintiff and Dr. Williamson agree to file an Updated Status Report and Proposed Discovery Plan Regarding the Medical Claims following the filing of Plaintiff's second amended complaint which will provide an exact due date for dispositive motions.

IT IS SO ORDERED