Fitzpatrick et al v. Las Vegas Metropolitan Police Department, et al

Filing 38

ORDER Granting 36 Stipulation to Extend Time to Answer/Respond re: 32 Amended Complaint. Angelo Larry answer due 3/19/2018; Las Vegas Metropolitan Police Department answer due 3/19/2018; Rolando Trevino answer due 3/19/2018. Signed by Magistrate Judge Peggy A. Leen on 3/13/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01886-JAD-PAL Document 36 Filed 03/12/18 Page 1 of 3

1 ROBERT W. FREEMAN
Nevada Bar No. 3062
2 [e-mail]
LEWIS BRISBOIS BISGAARD & SMITH LLP
3 6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
4 702.893.3383
FAX: [phone]
Attorneys for Defendants
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Las Vegas Metropolitan Police
Department, Corrections Officer
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Angelo Larry and Corrections Officer
Rolando Trevino
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8

UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA, SOUTHERN DIVISION

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***

11 PATRICIA FITZPATRICK and ROBERT L.
ANSARA, as Special Co-Administrators and
12 Special Representatives of the Estate of
JERREMIAH BOWLING, deceased; and
13 PATRICIA FITZPATRICK, as Heir and
Mother of JEREMIAH BOWLING, deceased,
14
Plaintiff,
15
vs.
16
17 LAS VEGAS METROPOLITIAN POLICE
DEPARTMENT, a political subdivision of the
18 State of Nevada; ANGELO LARRY,
Corrections Officer, individually and in his
19 official capacity; ROLANDO TREVINO,
Corrections Officer, individually and in his
20 official capacity; DOES 1 through 10,
individually and/or in their official capacities;
21 DOE CLASSIFICATION OFFICERS I
through 10, individually and/or in their official
22 capacities; DOE CORRECTIONS OFFICERS
I through 10, individually and/or in their
23 official capacities; ROE CORPORATIONS I
through 10, Foreign and/or Domestic
24 Corporations, NAPHCARE, INC., an Alabama
corporation qualified to do business in the
25 State of Nevada; DOE HEALTH CARE
PROVIDERS1 through 10, individually,
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Defendants.
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LEWIS

28

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4812-6821-8463.1

CASE NO. 2:17-cv-1886-JAD-PAL
STIPULATION AND ORDER
EXTENDING THE DEADLINE FOR THE
FILING OF DEFENDANTS LAS VEGAS
METROPOLITAN POLICE
DEPARTMENT, CORRECTIONS
OFFICER ANGELO LARRY AND
CORRECTIONS OFFICER ROLANDO
TREVINO ANSWER TO PLAINTIFFS’
SECOND AMENDED COMPLAINT

Case 2:17-cv-01886-JAD-PAL Document 36 Filed 03/12/18 Page 2 of 3

1

STIPULATION AND ORDER EXTENDING THE DEADLINE
FOR THE FILING OF DEFENDANTS LAS VEGAS METROPOLITAN
POLICE DEPARTMENT, CORRECTIONS OFFICER ANGELO LARRY
AND CORRECTIONS OFFICER ROLANDO TREVINO’S
ANSWER TO PLAINTIFFS’ SECOND AMENDED COMPLAINT

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3

IT IS HEREBY STIPULATED AND AGREED, by and between Robert W. Freeman, Esq.

4

5 of LEWIS BRISBOIS BISGAARD & SMITH LLP, counsel for Defendants Las Vegas
6 Metropolitan Police Department, Corrections Officer Angelo Larry and Corrections Officer
7 Rolando Trevino and Nadine M. Morton, Esq., of MORTON LAW, PLLC, counsel for Plaintiffs
8 Patricia Fitzpatrick and Robert L. Ansara, as Special Co-Administrators and Special
9 Representatives of the Estate of Jerremiah Bowling, deceased; and Patricia Fitzpatrick, as Heir and
10 Mother of Jeremiah Bowling, that:
The due date for Defendants’ Answer to Plaintiffs’ Second Amended Complaint (ECF No.

11

12 32), be extended from March 12, 2018, to March 19, 2018.
13

Reason for the Extension:

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Because of the complexity of the claims made in Plaintiffs’ Amended Complaint,

15 Defendants need additional time to perform an investigation prior to filing a responsive pleading.
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LEWIS

28 …

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4812-6821-8463.1

2

Case 2:17-cv-01886-JAD-PAL Document 36 Filed 03/12/18 Page 3 of 3

1 This is the first request to extend this deadline, which is made in good faith and not for purposes
2 of delay.
3 DATED this 12th day of March, 2018.

DATED this 12th day of March 2018.

4 MORTON LAW, PLLC

LEWIS BRISBOIS BISGAARD & SMITH

5
6 /s/ Nadine M. Morton
Nadine M. Morton, Esq.
7 Nevada Bar No. 8583
11700 West Charleston Blvd.
8 Suite 170-65
Las Vegas, Nevada 89135
9
Attorney for Plaintiffs
10

/s/ Robert W. Freeman
Robert W. Freeman, Jr., Esq.
Nevada Bar No. 3062
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendants

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IT IS SO ORDERED:

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____________________________________
UNITED STATES MAGISTRATE JUDGE

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March 13, 2018
DATED: ________________________

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LEWIS

28

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4812-6821-8463.1

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