Opinion
2:21-cv-01334-RFB-BNW
11-04-2022
ROBERT COACHE, an Individual, Plaintiff, v. MARC DIGIACOMO, 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, Defendants.
LYSSA S. ANDERSON KRISTOPHER J. KALKOWSKI KAEMPFER CROWELL Attorneys for Defendants, Colin Haynes, Lt. Nathan Chio RALPH A. SCHWARTZ, PC RALPH A. SCHWARTZ EDWIN B. BROWN (Admitted Pro Hac Vice) BROWN CLARK LE AMES STEDMAN & CEVALLOS LLP Attorneys for Plaintiff, Robert Coache CLARK COUNTY DISTRICT ATTORNEY STEVEN B. WOLFSON SCOTT DAVIS TIMOTHY ALLEN Attorneys for Marc DiGiacomo
LYSSA S. ANDERSON
KRISTOPHER J. KALKOWSKI
KAEMPFER CROWELL
Attorneys for Defendants, Colin Haynes, Lt. Nathan Chio
RALPH A. SCHWARTZ, PC
RALPH A. SCHWARTZ
EDWIN B. BROWN
(Admitted Pro Hac Vice)
BROWN CLARK LE AMES STEDMAN & CEVALLOS LLP
Attorneys for Plaintiff, Robert Coache
CLARK COUNTY DISTRICT ATTORNEY
STEVEN B. WOLFSON
SCOTT DAVIS
TIMOTHY ALLEN
Attorneys for Marc DiGiacomo
STIPULATION, REQUEST AND ORDER EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S AMENDED COMPLAINT
(FIRST REQUEST)
RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE
Defendants, Colin Haynes and Lt. Nathan Chio (“LVMPD Defendants”), by and through their counsel Kaempfer Crowell, Defendant Marc DiGiacomo, by and through his counsel Deputy District Attorney, Scott Davis, and Plaintiff, Robert Coache, by and through his counsel Ralph Schwartz from Ralph Schwartz, PC and Edwin Brown from Brown Clark Le Ames Stedman & Cevallos LLP, hereby respectfully submit this Stipulation, Request and Order Extending Time to Answer or Otherwise Respond to Plaintiff's Amended Complaint (the “Stipulation”). This Stipulation is made in accordance with LR 6-1, LR 6-2, and LR II 7-1 of the Local Rules of this Court. This is the first request for an extension of time to file an answer or otherwise respond to Plaintiff's Amended Complaint.
The LVMPD Defendants and DiGiacomo were served with Plaintiff's Amended Complaint on November 1, 2022 via CM/ECF. The instant extension is requested as the Defendants' Counsel require additional time to prepare a responsive pleading to the Plaintiff's Amended Complaint.
Upon agreement by and between all the parties hereto as set forth herein, the undersigned respectfully requests this Court grant an extension of time, up to and including November 29, 2022, for Defendants to file an answer or otherwise respond to Plaintiff's Amended Complaint. By entering into this Stipulation, none of the parties waive any rights they have under statute, law or rule with respect to Plaintiff's Amended Complaint.
ORDER
IT IS SO ORDERED.