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)

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Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 1 of 3 1 7 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 (702) 222-0007 Fax (702) 222-0001 Lisa@Veldlaw.com, Richard@Veldlaw.com, Kristina@Veldlaw.com 8 Attorneys for Plaintiff, Frank LaPena 2 3 4 5 6 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 11 12 13 14 15 16 17 18 19 FRANK LAPENA, ) ) Plaintiff, ) ) vs. ) ) LAS VEGAS METROPOLITAN POLICE ) DEPARTMENT, a government entity; et al ) ) Defendants. ) ) ) ) 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 20 Rasmussen and the Law Offices of Kristina Wildeveld & Associates and hereby moves this 21 Court for an Order extending the time for him to file a Response to Clark County and te Clark 22 County DA Defendants’ Motion for Partial Judgment on the Pleadings, filed on December 16, 23 2021 at ECF 8 for a period of three weeks, until January 27, 2022. This Motion is unopposed by 24 counsel for the Clark County and Clark County DA defendants and is based upon the following: 25 1. Mr. LaPena filed an Amended Complaint on today’s date. [See ECF 24.] 26 2. Counsel for Mr. LaPena wanted to give opposing counsel for all defendants an 27 opportunity to determine whether they wanted an opportunity to amend their pending 28 motions in light of the Amended Complaint. 1 Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 2 of 3 1 3. The undersigned has conferred with counsel for the Clark Countydefendants and he is 2 not opposed to this request for an extension of three weeks (21 days), until January 3 27, 2022 to file a Response absent any additional stipulations that the parties may 4 enter. 5 4. Denial of this request would cause prejudice to Mr. LaPena. Additionally, this 6 Motion is not made for the purpose of delay and is made in good faith. The 7 undersigned has diligently worked to file an Amended Complaint that will make 8 some of the issues easier for this Court to ultimately determine. 9 Accordingly, it is respectfully requested that this Court enter an Order authorizing Mr. 10 LaPena to file is response to the Clark County Defendants’ Motion on or before January 27, 11 2022. 12 DATED this 6th day of January 2022. 13 Respectfully Submitted By: 14 15 /s/ Lisa A. Rasmussen LISA A. RASMUSSEN, ESQ. Nevada Bar No. 007491 Attorneys for Plaintiff, Frank LaPena 16 17 18 19 ORDER 20 Upon the unopposed Motion of Plaintiff, and good cause appearing, 21 IT IS HEREBY ORDERED that Plaintiff shall have until January 27, 2022 to file his 22 23 24 25 26 27 28 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 2 Case 2:21-cv-02170-JCM-NJK Document 46 Filed 01/10/22 Page 3 of 3 CERTIFICATE OF SERVICE 1 2 I HEREBY CERTIFY that I served a copy of the foregoing, PLAINTIFF’S 3 UNOPPOSED MOTION FOR EOT RE: CLARK COUNTY’S PARTIAL MOTION FOR 4 JUDGMENT, upon the following persons, via CM/ECF, this Court’s mandated electronic filing 5 system: 6 7 8 9 10 11 12 13 14 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. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

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