Opinion

Brown v. Tromba

Court
District Court, D. Nevada
Filed
Jul 19, 2022
Cited by
0 cases

The opinion

District Attorney

2 CIVIL DIVISION

State Bar No. 001565

3 By: JEFFREY S. ROGAN

Deputy District Attorney

4 State Bar No. 010734

500 South Grand Central Pkwy. 5th Flr.

5 Las Vegas, Nevada 89155-2215

Telephone: (702) 455-4761

6 Fax: (702) 382-5178

E-Mail: Jeffrey.Rogan@ClarkCountyDA.com

7 Attorneys for Defendants Clark County,

the Clark County District Attorney’s Office,

8 and Steve Wolfson

9 UNITED STATES DISTRICT COURT

10 DISTRICT OF NEVADA

11 Marlon Lorenzo Brown, )

)

12 Plaintiff, ) Case No: 2:17-cv-02396-APG-BNW

)

13 vs. )

)

14 City Of Las Vegas, Nevada; Las Vegas ) STIPULATION TO STAY

Metropolitan Police Department ) DISCOVERY

15 (LVMPD); Clark County; Clark County )

District Attorney’s Office; Steve )

16 WOLFSON; Danae Adams; Bruce Nelson; )

Joseph Lombardo; Dante Tromba; Does )

17 and Roes 1-20, )

)

18 Defendants. )

)

19

20 Defendants Clark County, the Clark County District Attorney’s Office, and Clark

21 County District Attorney Steve Wolfson (the “County Defendants”); the Las Vegas

22 Metropolitan Police Department and Dante Trombe (“LVMPD Defendants”); and Marlon

23 Lorenzo Brown (“Plaintiff”), hereby stipulate as follows:

24 1) Discovery shall be stayed pending ruling on the County Defendants’ and LVMPD

25 Defendants’ Motions to Dismiss, [ECF Nos. 101 and 105], subject to potential lifting of the

26 stay upon terms and conditions that the parties and the court deem just;

27 2) A stay is necessary because these pending Motions involve issues of immunity and

28 adequacy of pleading allegations, and resolution of these Motions does not require further

1 || discovery. Pilger v. Mosley, No. 2:18-cv-00854-JAD-PAL, 2018 WL 5268605, at *2 (D. Ne

2 Oct. 23, 2018) (“The Supreme Court has squarely held that until the threshold issue «

3 ||immunity is resolved, discovery should not proceed.”). A stay of discovery at this time wi

4 ||align with Federal Rule of Civil Procedure 1, which declares that the Rules “should |

5 ||construed, administered, and employed by the court and the parties to secure the jus

6 || speedy, and inexpensive determination of every action and proceeding.”

7 3) The discovery stay shall include all discovery previously served but for which r

8 || response has been made;

9 4) The parties agree that any responses to any outstanding discovery will be made withi

10 || fourteen (14) days of the Court’s ruling on any applicable Motion to Dismiss; if necessary.

11 5) The parties will submit a new proposed Discovery Plan to the Court within fourtee

12 || (14) days of the Court’s ruling on the last filed Motion to Dismiss and the stay will be lifte

13 ||The new discovery plan will include extended deadlines to designate experts, condu

14 || discovery, and file dispositive motions.

15 DATED this 15th day of July, 2022.

16 || KAEMPFER CROWELL MCAVOY AMAYA & REVERO

17 || By: s/Kristopher J. Kalkowski By: s/Michael J. McAvoy-Amaya

LYSSA S. ANDERSON MICHAEL J. McAVOY-AMAYA

18 Nevada Bar No. 5781 Nevada Bar No. 14082

KRISTOPHER J. KALKOWSKI TIMOTHY E. REVERO

19 Nevada Bar No. 14892 Nevada Bar No. 14603

1980 Festival Plaza Drive 400 S. 4th St., Ste. 500

20 Suite 650 Las Vegas, NV 89101

Las Vegas, Nevada 89135 Attorneys for Plaintiff

21 Attorneys for Defendants

Las Vegas Metropolitan Police

22 Devartment and Dante Tromba ORDER

23 11 CLARK COUNTY IT IS SO ORDERED

DATED: 3:56 pm, July 18, 2022

24 || By: 4 Jeffrey S. Rogan

JEFFREY S. ROGAN bao

25 Deputy District Attorney Sr BNE

Nevada Bar No. 010734 BRENDA WEKSLER

26 500 South Grand Central Pkwy. UNITED STATES MAGISTRATE JUDGE

Las Vegas, Nevada 89155-2215

27 Attorney for Defendants Clark

8 County, the Clark County District

2 Attorney’s Office, and Steve

Wolfson

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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