Case Information
*1 LYSSA S. ANDERSON
Nevada Bar No. 5781
KRISTOPHER J. KALKOWSKI
Nevada Bar No. 14892
TRAVIS C. STUDDARD
Nevada Bar No. 16454
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135
Telephone: (702) 792-7000
Fax: (702) 796-7181
landerson@kcnvlaw.com
kkalkowski@kcnvlaw.com tstuddard@kcnvlaw.com
Angie Santos and Las Vegas Metropolitan Police Department
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA KRISTINA KERLUS, individually, Case No.: 2:24-cv-02352-APG-DJA Plaintiff,
vs. STIPULATION TO EXTEND TIME TO
FILE A RESPONSE TO LAS VEGAS DR. JENNIFER CORNEAL, in her individual METROPOLITAN POLICE capacity; A. SANTOS, in her individual DEPARTMENT’S MOTION TO DISMISS capacity; CITY OF LAS VEGAS, a Municipal [ECF No. 44] corporation; and COUNTY OF CLARK, a
Municipal corporation; LAS VEGAS (Second Request) METROPOLITAN POLICE DEPARTMENT,
jointly and severally
Defendants.
Defendant, Las Vegas Metropolitan Police Department (“LVMPD”), by and through its counsel, Lyssa S. Anderson, and Plaintiff, Kristina Kerlus (“Plaintiff”), by and through her counsel, Patrick Driscoll, stipulate and agree to extend the current deadline of June 24, 2025, for Plaintiff to file a Response to Las Vegas Metropolitan Police Department’s Motion to Dismiss [ECF No. 44] for an additional thirty (30) days, which will create a new deadline of July 24, 2025 . *2 1. On May 27, 2025, Defendant Las Vegas Metropolitan Police Department (“LVMPD”) filed a Motion to Dismiss. [ECF No. 44].
2. On June 4, 2025, the parties filed a Stipulation, Request and Order Extending Time to Respond to Defendant LVMPD’s Motion to Dismiss [ECF No. 44] (First Request). [ECF No. 52]. The parties sought an extension of the deadline for Plaintiff to respond to the Motion to Dismiss until June 24, 2025.
3. On June 5, 2025, the Court granted the Stipulation. [ECF No. 53].
4. On June 18, 2025, the parties held a telephone conference where counsel for Plaintiff indicated that they would be seeking leave to amend the operative complaint based upon certain circumstances associated with its filing.
5. Federal Rule of Civil Procedure 6(b) and Local Rule IA 6-1 impose a good cause standard to extend the deadline file a response to the Motion to Dismiss. “‘Good cause’ is a non- rigorous standard that has been construed broadly across procedural and statutory contexts.” Ahanchian v. Xenon Pictures , Inc., 624 F.3d 1253, 1259 (9th Cir. 2010).
6. Good cause exists to extend the deadline for Plaintiff to file a response to the Motion to Dismiss based upon the representation by Plaintiff’s counsel that they intend to seek leave to amend the complaint. While LVMPD Defendants neither stipulate to the amendment of the Complaint, nor waive their rights associated with the pending Motion to Dismiss, allowing Plaintiff to seek leave from the Court before responding to the Motion will conserve the expenditure of fees and judicial economy in the event that the Court permits amendment. / / /
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/ / / *3 DATED this 23rd day of June, 2025. PAUL PADDA LAW
By: /s/ Lyssa S. Anderson By: /s/ Patrick J. Driscoll LYSSA S. ANDERSON (5781) PAUL S. PADDA (10417) KRISTOPHER J. KALKOWSKI (14892) RAVI CHANDERRAJ (8400) TRAVIS C. STUDDARD (16454) 4560 South Decatur Blvd., #300 1980 Festival Plaza Drive, # 650 Las Vegas, NV 89103 Las Vegas, Nevada 89135 – and – Las Vegas Metropolitan Police ANTONIO M. ROMANUCCI Department (Admitted PHV)
PATRICK DRISCOLL (Admitted PHV) 321 N. Clark Street, Suite 900 Chicago, IL 60654 Attorneys for Plaintiff ORDER
IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE Dated: June 24, 2025 6943.335