Opinion
2:20-cv-00769-GMN-DJA
04-28-2022
KEYHERRA GREEN, Plaintiff, v. LAS VEGAS METROPOLITAN POLICE DEPARTMENT; FRED MERRICK; LORA CODY; and DOES 1-10, inclusive, Defendants.
KAEMPFER CROWELL, LYSSA S. ANDERSON, RYAN W. DANIELS Attorneys for Defendant Las Vegas Metropolitan Police Department, Fred Merrick; and Lora Cody PETER GOLDSTEIN LAW CORP, Peter Goldstein And MALCOM P. LAVERGNE & ASSOCIATES, Malcom P. LaVergne Attorneys for Plaintiff.
KAEMPFER CROWELL, LYSSA S. ANDERSON, RYAN W. DANIELS Attorneys for Defendant Las Vegas Metropolitan Police Department, Fred Merrick; and Lora Cody
PETER GOLDSTEIN LAW CORP, Peter Goldstein And MALCOM P. LAVERGNE & ASSOCIATES, Malcom P. LaVergne Attorneys for Plaintiff.
STIPULATION, REQUEST AND ORDER EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S THIRD AMENDED COMPLAINT
Defendants, Las Vegas Metropolitan Police Department, Fred Merrick and Lora Cody (“LVMPD Defendants”), by and through their counsel, Kaempfer Crowell, and Plaintiff, Keyherra Green (“Plaintiff”), by and through her counsel, Peter Goldstein, hereby respectfully submit this Stipulation, Request and Order Extending Time to Answer or Otherwise Respond to Plaintiff's Third Amended Complaint 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 Third Amended Complaint.
Plaintiff filed her Third Amended Complaint (“TAC”) on April 13, 2022, [ECF No. 74]. The TAC is sixty-eight (68) pages and contains three hundred and seventy-seven (377) paragraphs. The instant extension is requested as LVMPD Defendants' Counsel requires additional time to prepare a responsive pleading to the TAC.
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 Monday, May 2, 2022, for LVMPD Defendants to file an answer or otherwise respond to Plaintiff's TAC. By entering into this Stipulation, none of the parties waive any rights they have under statute, law or rule with respect to Plaintiff's TAC.
ORDER
IT IS SO ORDERED.