Coache v. Las Vegas Metropolitan Police Department et al

Filing 28

ORDER granting 27 Motion to Extend Time Re: 1 Complaint. Nathan Chio answer due 12/6/2021; Colin Haynes answer due 12/6/2021; Las Vegas Metropolitan Police Department answer due 12/6/2021. Signed by Magistrate Judge Brenda Weksler on 11/18/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Case 2:21-cv-01334-RFB-BNW Document 27 Filed 11/17/21 Page 1 of 3 1 2 3 4 5 6 7 LYSSA S. ANDERSON Nevada Bar No. 5781 KRISTOPHER J. KALKOWSKI Nevada Bar No. 14892 KAEMPFER CROWELL 1980 Festival Plaza Drive, Suite 650 Las Vegas, Nevada 89135 Telephone: (702) 792-7000 Fax: (702) 796-7181 landerson@kcnvlaw.com kkalkowski@kcnvlaw.com Attorneys for Defendants, Las Vegas Metropolitan Police Department, Colin Haynes, Lt. Nathan Chio 8 UNITED STATES DISTRICT COURT 9 10 DISTRICT OF NEVADA ROBERT COACHE, an Individual, 11 Plaintiff, 12 vs. 13 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a government entity; CLARK COUNTY, a political subdivision of the State of Nevada and a government entity: MARC DIGIACOMO, an individual and an employee of a government entity; SARAH E. OVERLY, an individual and an employee of a government entity; COLIN HAYNES, an individual and an employee of a government entity; NATHAN CHIO, an individual and an employee of a government entity; and DOES 1-30, 14 15 16 17 18 Case No.: 2:21-cv-01334-RFB-BNW 19 JOINT MOTION TO EXTEND TIME FOR LVMPD DEFENDANTS TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT (FIRST REQUEST) Defendants. 20 21 Defendants Las Vegas Metropolitan Police Department, Colin Haynes and Lt. 22 Nathan Chio (collectively “LVMPD Defendants”), by and through their counsel Kaempfer 23 Crowell, and Plaintiff Robert Coache, by and through his counsel Ralph Schwartz from Ralph 24 Schwartz, PC and Edwin Brown from Brown Clark Le Ames Stedman & Cevallos LLP (Pro KAEMPFER CROWELL 1980 Festival Plaza Drive Suite 650 Las Vegas, Nevada 89135 2980968_1 6943.254 Page 1 of 3 Case 2:21-cv-01334-RFB-BNW Document 27 Filed 11/17/21 Page 2 of 3 1 Hac Vice pending) submit this Joint Motion to Extend Time for LVMPD Defendants to Answer 2 or Otherwise Respond to the Complaint (First Request). 3 1. On July 14, 2021, Plaintiff filed his Complaint. The LVMPD Defendants were 4 served on November 1, 2021. The current deadline for LVMPD Defendants to answer or 5 otherwise respond by motion to Plaintiff’s Complaint is November 22, 2021. 6 2. On Wednesday, November 10, 2021, counsel for LVMPD Defendants 7 communicated with Plaintiff’s Counsel via phone regarding a two-week extension within which 8 to file a response to the Complaint, and Plaintiff’s Counsel agreed to the extension. 9 3. The requested extension is necessary to ensure that LVMPD Defendants’ Counsel 10 has adequate time to review all pleading allegations, accurately respond to each, and form 11 defenses at this preliminary stage. 12 4. This Joint Motion is made in good faith and not for the purposes of delay. 13 5. Plaintiff has agreed to extend the deadline in which LVMPD Defendants respond 14 by motion or pleading to Plaintiff’s Complaint up to and including December 6, 2021. This is the 15 first motion for extension of time for LVMPD Defendants to respond to Plaintiff’s Complaint 16 DATED this 17th day of November, 2021. 17 KAEMPFER CROWELL RALPH A. SCHWARTZ, PC 18 By: /s/ Lyssa S. Anderson LYSSA S. ANDERSON Nevada Bar No. 5781 KRISTOPHER J. KALKOWSKI Nevada Bar No. 14892 1980 Festival Plaza Drive, #650 Las Vegas, Nevada 89135 Attorneys for Defendants, Las Vegas Metropolitan Police Department, Colin Haynes, Lt. Nathan Chio Order By: /s/ Ralph A. Schwartz RALPH A. SCHWARTZ Nevada Bar No. 5488 400 S. 7th Street, Suite 100 Las Vegas, NV 89101 19 20 21 22 23 24 KAEMPFER CROWELL 1980 Festival Plaza Drive Suite 650 Las Vegas, Nevada 89135 IT IS SO ORDERED EDWIN B. BROWN (Pro Hac Vice Pending) California Bar No. 89447 BROWN CLARK LE AMES STEDMAN & CEVALLOS LLP 22342 Avenida Empresa, Ste. 125 Rancho Santa Margarita, CA 92688 Attorneys for Plaintiff, Robert Coache DATED: 4:46 pm, November 18, 2021 2980968_1 6943.254 BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE Page 2 of 3

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