Opinion
2:21-cv-2170 JCM-NJK
01-10-2022
FRANK LAPENA, Plaintiff, v. LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a government entity; et al Defendants.
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 Attorneys for Plaintiff, Frank LaPena Mr. Thomas Dillard, Esq. Counsel for Clark County and the CCDA Defendants Mr. Craig Anderson, Esq. Counsel for the LVMPD defendants
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 & ASSOCIATESAttorneys for Plaintiff, Frank LaPena
Mr. Thomas Dillard, Esq. Counsel for Clark County and the CCDA Defendants
Mr. Craig Anderson, Esq. Counsel for the LVMPD defendants
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]
THE HONORABLE JAMES C. MAHAN UNITED STATES DISTRICT JUDGE
COMES NOW the Plaintiff, FRANK LAPENA, by and through his counsel, Lisa Rasmussen and the Law Offices of Kristina Wildeveld & Associates and hereby moves this Court for an Order extending the time for him to file a Response to Clark County and te Clark County DA Defendants' Motion for Partial Judgment on the Pleadings, filed on December 16, 2021 at ECF 8 for a period of three weeks, until January 27, 2022. This Motion is unopposed by counsel for the Clark County and Clark County DA defendants and is based upon the following:
1. Mr. LaPena filed an Amended Complaint on today's date. [See ECF 24.]
2. Counsel for Mr. LaPena wanted to give opposing counsel for all defendants an opportunity to determine whether they wanted an opportunity to amend their pending motions in light of the Amended Complaint.
3. The undersigned has conferred with counsel for the Clark Countydefendants and he is not opposed to this request for an extension of three weeks (21 days), until January 27, 2022 to file a Response absent any additional stipulations that the parties may enter.
4. Denial of this request would cause prejudice to Mr. LaPena. Additionally, this Motion is not made for the purpose of delay and is made in good faith. The undersigned has diligently worked to file an Amended Complaint that will make some of the issues easier for this Court to ultimately determine.
Accordingly, it is respectfully requested that this Court enter an Order authorizing Mr. LaPena to file is response to the Clark County Defendants' Motion on or before January 27, 2022.
ORDER
Upon the unopposed Motion of Plaintiff, and good cause appearing, IT IS HEREBY ORDERED that Plaintiff shall have until January 27, 2022 to file his response to the Clark County Defendants' Motion for Partial Judgment on the Pleadings (ECF 8).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a copy of the foregoing, PLAINTIFF'S UNOPPOSED MOTION FOR EOT RE: CLARK COUNTY'S PARTIAL MOTION FOR JUDGMENT, upon the following persons, via CM/ECF, this Court's mandated electronic filing system: