Brennan v. Las Vegas Metropolitan Police Department et al

Filing 43

ORDER Granting 42 Stipulation for Extension of Time (First Request) re 36 Motion for Partial Summary Judgment. Responses due by 6/25/2021. Signed by Judge Richard F. Boulware, II on 6/4/2021. (Copies have been distributed pursuant to the NEF - YAW)

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CRAIG A. MUELLER, ESQ.
Nevada Bar No.: 4703
MUELLER & ASSOCIATES, INC.
808 South Seventh Street
Las Vegas, NV 89101
P: [phone] | F: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HELEN BRENNAN, individually
Plaintiff,
vs.

CASE NO.: 2: 20-cv-00662-RFB-DJA

STATE OF NEVADA ex rel LAS VEGAS
METROPOLITAN POLICE
DEPARTMENT, a political subdivision of
the State of Nevada; STATE OF NEVADA
ex rel NEVADA HIGHWAY PATROL, a
political subdivision of the State of Nevada;
TROOPER L. McCOLL, P#352, an
individual employed by STATE OF
NEVADA ex rel NEVADA HIGHWAY
PATROL, a political subdivision of the State
of Nevada; DOE TROOPERS I through XX,
employed by STATE OF NEVADA ex rel
NEVADA HIGHWAY PATROL, a political
subdivision of the State of Nevada; DOE
OFFICERS I through XX, employed by
STATE OF NEVADA ex rel ex rel LAS
VEGAS METROPOLITAN POLICE
DEPARTMENT, a political subdivision of
the State of Nevada; DOES I through X; and
ROE Business Entities I through X;
inclusive,
Defendants.

STIPULATION AND PROPOSED
ORDER TO EXTEND THE TIME IN
WHICH THE PLAINTIFF MAY
RESPOND TO DEFENDANTS LAS
VEGAS METROPOLITAN POLICE
DEPARTMENT’S MOTION FOR
PARTIAL SUMMARY JUDGMENT ON
PLAINTIFF’S MONELL CLAIM
(FIRST REQUEST)

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Plaintiff, HELEN BRENNAN and Defendants LAS VEGAS METROPOLITAN

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POLICE DEPARTMENT, by and through their respective counsel, hereby stipulate and agree as

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follows:

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1.

On May 21, 2021, Defendant, LAS VEGAS METROPOLITAN POLICE

DEPARTMENT filed Defendants Las Vegas Metropolitan Police Department’s Motion For
Page 1 of 2

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Partial Summary Judgment On Plaintiff’s Monell Claim, District of Nevada, designated Case No,:

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2: 20-cv-00662-RFB-DJA, ECF No. 36.

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2.

On, May 21, 2021, the court ordered a response due by June 11, 2021.

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3.

From the time of receiving the Defendant’s Motion, Lead Civil Attorney Laura

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Ungaro had already been on a medical leave from the firm with no return date, and civil paralegal

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Susie Ward contracted COVID-19 on May 26, 2021 whom is most familiar to this matter.

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4.

The Plaintiff requested an additional two weeks to get their new Civil Attorney up

to speed to this matter to draft the response making the new proposed deadline June 25, 2021.
5.

This is the first request for an extension regarding the filing of Plaintiffs response

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to Defendant’s Motion for Partial Summary Judgment, which is made in good faith, not for the

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purposes of delay, and neither party is prejudiced by the short extension.

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DATED this 3rd day of June, 2021.

DATED this 3rd day of June, 2021.

MUELLER & ASSOCIATES, INC.

KAEMPFER CROWELL

/s/ Craig A. Mueller, Esq.
_____________________________
CRAIG A. MUELLER, ESQ.
Nevada Bar No. 4703
808 South Seventh Street
Las Vegas, NV 89101
Attorney for Plaintiff

/s/ Lyssa S. Anderson, Esq.
______________________________
LYSSA S. ANDERSON, ESQ.
Nevada Bar No. 5781
1980 Festival Plaza Drive, Suite 650
Las Vegas, NV 89135
Attorney for Las Vegas Metropolitan
Police Department

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IT IS SO ORDERED.
DATED this ___ day of June, 2021.
4th
_____________________________________
UNITED STATES MAGISTRATE JUDGE

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Page 2 of 2

From:
To:
Subject:
Date:

Lyssa Anderson
Susie Ward
RE: Brennan- Extension Request
Thursday, June 3, 2021 12:44:38 PM

Susie,

You may use my e-signature to file.

Lyssa S. Anderson
Kaempfer Crowell
1980 Festival Plaza Drive, Suite 650
Las Vegas, NV 89135-2958
Tel:  [phone]
Fax:  [phone]
Email: [e-mail]
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From: Susie Ward [mailto:[e-mail]]
Sent: Thursday, June 3, 2021 12:22 PM
To: Lyssa Anderson
Subject: RE: Brennan- Extension Request

Please review the attached proposed order, thank you for this.

Sincerely,

Susie Ward
Paralegal,
Mueller and Associates
th

808 S. 7 Street
Las Vegas, NV 89101
P- 702-382-1200
F- 702-637-4817
[e-mail]

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From: Lyssa Anderson <[e-mail]>
Sent: Thursday, June 3, 2021 10:37 AM
To: Susie Ward <[e-mail]>
Subject: Re: Brennan- Extension Request

That’s fine.  Please send us a proposed stipulation.

Hope you are well.  
Best Regards,
Lyssa S. Anderson

On Jun 3, 2021, at 10:32 AM, Susie Ward <[e-mail]> wrote:

Lyssa,

Would you stipulate to an extension on our opposition for two weeks making it due the
25th if the court will allow it? I am out on quarantine and Laura Ungaro is not coming
back to the firm for medical issues. I just finally got a new civil attorney that needs to
get up to speed on this matter. Please let me know so I can get the stipulation to you,
thank you.

Sincerely,

Susie Ward

Paralegal,
Mueller and Associates
808 S. 7th Street
Las Vegas, NV 89101
P- 702-382-1200
F- 702-637-4817
[e-mail]

Confidentiality Note: The information in this e-mail is confidential and may be legally privileged. It is
intended solely for the addressees. Access to this e-mail by anyone other than the recipient is unauthorized.
This communication may contain information that is proprietary, privileged or confidential or otherwise
legally exempt from disclosure. If you are not the intended recipient, any disclosure, reproduction,
distribution, or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful.
If you have received this message in error, please notify the sender immediately by e-mail and delete all
copies of the message.