Opinion
2:23-cv-00487-JCM-DJA
04-27-2023
GODFREY MERE, an individual, Plaintiff, v. STATE OF NEVADA, Desert Willow Treatment Center; DR. GWENDOLYN GREENE, Administrator, Desert Willow Treatment Center; RONNIKA RUPERT, Director of Nursing, Desert Willow Treatment Center; ALBIE JERKINS, Quality Assurance Director, Desert Willow Treatment Center; DOES 1-00 and ROES I-X, inclusive, Defendants.
AARON FORD Attorney General PAUL MATA Deputy Attorney General Nevada Attorney for Defendants. GUINNESS LAW FIRM GUINNESS OHAZURUIKE, ESQ. Attorney for Plaintiff AARON FORD Attorney General PAUL MATA Deputy Attorney General Office of the Attorney General Attorneys for Defendants State of Nevada, Department of Health And Human Services, Division of Child and Family Services, Desert Willow Treatment Center; Dr. Gwendolyn Greene; Ronnika Rupert, and Abbie Jenkins
AARON FORD Attorney General PAUL MATA Deputy Attorney General Nevada Attorney for Defendants.
GUINNESS LAW FIRM GUINNESS OHAZURUIKE, ESQ. Attorney for Plaintiff
AARON FORD Attorney General PAUL MATA Deputy Attorney General Office of the Attorney General Attorneys for Defendants State of Nevada, Department of Health And Human Services, Division of Child and Family Services, Desert Willow Treatment Center; Dr. Gwendolyn Greene; Ronnika Rupert, and Abbie Jenkins
STIPULATION, REQUEST AND ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO PLAINTIFF'S COMPLAINT [FIRST REQUEST]
Pursuant to LR 6-1, Plaintiff GODFREY MERE (“Plaintiff”), by and through his counsel of record, GUINNESS OHAZURUIKE, ESQ. of the Guinness Law Firm, and Defendants STATE OF NEVADA, DEPARTMENT OF HEALTH AND HUMAN SERVICES, DIVISION OF CHILD AND FAMILY SERVICES, DESERT WILLOW TREATMENT CENTER; DR. GWENDOLYN GREENE; RONNIKA RUPERT; and ABBIE JENKINS (collectively “Defendants”), by and through their attorneys of record, AARON FORD, Attorney General for the State of Nevada, and PAUL MATA, Deputy Attorney General, hereby submit their Stipulation, Request, and Order Extending Time to Respond to Plaintiff Godfrey Mere's Complaint. This is the first request for an extension of time to file a response by the Defendants.
Plaintiff Godfrey Mere filed his Complaint (ECF No. 1) on April 4, 2023 (the “Complaint”). Plaintiff served the individual defendants on April 6, 2023. Plaintiff served the State of Nevada Office of the Attorney General on April 10, 2023. Pursuant to Federal Rule of Civil Procedure 12(a), the current deadline for the Defendants to answer or otherwise respond to the Complaint is April 27, 2023, and May 1, 2023, respectively.
Mr. Mata is assigned to represent the Defendants but has only recently joined the Attorney General's Office and is getting up to speed on the facts of this matter. Additional time is also needed to review the 159 allegations with Mr. Mata's clients to prepare the appropriate response. Counsel for Defendants requested, and Plaintiff's Counsel has agreed, to a short extension of time for Defendants to respond to Plaintiff's Complaint.
Therefore, upon agreement by and between all the parties, through their respective counsel, the undersigned counsel requests that this Court grant the Defendants an extension of time, up to and including, Monday, May 8, 2023, to file a response to the Complaint.
By entering into this stipulation, none of the parties waive any rights they have under statute, law, or rule with respect to the Complaint.
APPROVED AS TO FORM AND CONTENT.
IT IS SO ORDERED.