LaPena v. Las Vegas Metropolitan Police Department et al

Filing 46

ORDER Granting #43 Unopposed Motion to Extend Time (First Request) re #8 Motion for Partial Judgment. Responses due by 1/27/2022. Signed by Judge James C. Mahan on 1/10/2022. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 1 of 3

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KRISTINA WILDEVELD, ESQ.
Nevada Bar No. 5825
LISA RASMUSSEN, ESQ.
Nevada Bar No. 7491
RICHARD BRYANT, ESQ
Nevada Bar No. 15511
THE LAW OFFICE OF KRISTINA WILDEVELD & ASSOCIATES
550 E. Charleston Blvd.,Suite A
Las Vegas, NV 89101
Phone [phone]
Fax [phone]
[e-mail], [e-mail],
[e-mail]

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Attorneys for Plaintiff, Frank LaPena

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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FRANK LAPENA,

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Plaintiff,
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vs.
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LAS VEGAS METROPOLITAN POLICE )
DEPARTMENT, a government entity; et al )
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Defendants.
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CASE NO. 2:21-cv-2170 JCM-NJK
DEPT. NO.
UNNOPPOSED MOTION TO EXTEND
TIME TO FILE RESPONSE TO CLARK
COUNTY AND CCDA DEFENDANTS’
PARTIAL MOTION FOR JUDGMENT ON
THE PLEADINGS [ECF 8]

COMES NOW the Plaintiff, FRANK LAPENA, by and through his counsel, Lisa

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Rasmussen and the Law Offices of Kristina Wildeveld & Associates and hereby moves this

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Court for an Order extending the time for him to file a Response to Clark County and te Clark

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County DA Defendants’ Motion for Partial Judgment on the Pleadings, filed on December 16,

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2021 at ECF 8 for a period of three weeks, until January 27, 2022. This Motion is unopposed by

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counsel for the Clark County and Clark County DA defendants and is based upon the following:

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1. Mr. LaPena filed an Amended Complaint on today’s date. [See ECF 24.]

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2. Counsel for Mr. LaPena wanted to give opposing counsel for all defendants an

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opportunity to determine whether they wanted an opportunity to amend their pending

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motions in light of the Amended Complaint.
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Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 2 of 3

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3. The undersigned has conferred with counsel for the Clark Countydefendants and he is

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not opposed to this request for an extension of three weeks (21 days), until January

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27, 2022 to file a Response absent any additional stipulations that the parties may

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enter.

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4. Denial of this request would cause prejudice to Mr. LaPena. Additionally, this

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Motion is not made for the purpose of delay and is made in good faith. The

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undersigned has diligently worked to file an Amended Complaint that will make

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some of the issues easier for this Court to ultimately determine.

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Accordingly, it is respectfully requested that this Court enter an Order authorizing Mr.

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LaPena to file is response to the Clark County Defendants’ Motion on or before January 27,

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2022.

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DATED this 6th day of January 2022.

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Respectfully Submitted By:

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/s/ Lisa A. Rasmussen
LISA A. RASMUSSEN, ESQ.
Nevada Bar No. 007491
Attorneys for Plaintiff, Frank LaPena

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ORDER

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Upon the unopposed Motion of Plaintiff, and good cause appearing,

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IT IS HEREBY ORDERED that Plaintiff shall have until January 27, 2022 to file his

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response to the Clark County Defendants’ Motion for Partial Judgment on the Pleadings (ECF
8).
January 10, 2022.
Dated: ____________
______________________________________
The Honorable James C. Mahan
United States District Judge

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Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 3 of 3

CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that I served a copy of the foregoing, PLAINTIFF’S

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UNOPPOSED MOTION FOR EOT RE: CLARK COUNTY’S PARTIAL MOTION FOR

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JUDGMENT, upon the following persons, via CM/ECF, this Court’s mandated electronic filing

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system:

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Mr. Thomas Dillard, Esq.
Counsel for Clark County and the CCDA Defendants
Mr. Craig Anderson, Esq.
Counsel for the LVMPD defendants
Dated this 6th day of January 2022.
/s/ Lisa A. Rasmussen
_______________________________
LISA A. RASMUSSEN, ESQ.

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