Kerlus v. Corneal

• Court: District Court, D. Nevada
• Decided: June 24, 2025
• Docket: 2:24-cv-02352
• Status: Unknown

Opinion

1 LYSSA S. ANDERSON Nevada Bar No. 5781 2 KRISTOPHER J. KALKOWSKI Nevada Bar No. 14892 3 TRAVIS C. STUDDARD Nevada Bar No. 16454 4 KAEMPFER CROWELL 1980 Festival Plaza Drive, Suite 650 5 Las Vegas, Nevada 89135 Telephone: (702) 792-7000 6 Fax: (702) 796-7181 landerson@kcnvlaw.com 7 kkalkowski@kcnvlaw.com tstuddard@kcnvlaw.com 8 Attorneys for Defendant 9 Angie Santos and Las Vegas Metropolitan Police Department

10 UNITED STATES DISTRICT COURT

11 DISTRICT OF NEVADA

12 KRISTINA KERLUS, individually, Case No.: 2:24-cv-02352-APG-DJA

13 Plaintiff, vs. STIPULATION TO EXTEND TIME TO 14 FILE A RESPONSE TO LAS VEGAS DR. JENNIFER CORNEAL, in her individual METROPOLITAN POLICE 15 capacity; A. SANTOS, in her individual DEPARTMENT’S MOTION TO DISMISS capacity; CITY OF LAS VEGAS, a Municipal [ECF No. 44] 16 corporation; and COUNTY OF CLARK, a Municipal corporation; LAS VEGAS (Second Request) 17 METROPOLITAN POLICE DEPARTMENT, jointly and severally 18 Defendants. 19

20 Defendant, Las Vegas Metropolitan Police Department (“LVMPD”), by and through its 21 counsel, Lyssa S. Anderson, and Plaintiff, Kristina Kerlus (“Plaintiff”), by and through her 22 counsel, Patrick Driscoll, stipulate and agree to extend the current deadline of June 24, 2025, for 23 Plaintiff to file a Response to Las Vegas Metropolitan Police Department’s Motion to Dismiss 24 [ECF No. 44] for an additional thirty (30) days, which will create a new deadline of July 24, 2025. 1 1. On May 27, 2025, Defendant Las Vegas Metropolitan Police Department 2 (“LVMPD”) filed a Motion to Dismiss. [ECF No. 44]. 3 2. On June 4, 2025, the parties filed a Stipulation, Request and Order Extending Time 4 to Respond to Defendant LVMPD’s Motion to Dismiss [ECF No. 44] (First Request). [ECF No.

5 52]. The parties sought an extension of the deadline for Plaintiff to respond to the Motion to 6 Dismiss until June 24, 2025. 7 3. On June 5, 2025, the Court granted the Stipulation. [ECF No. 53]. 8 4. On June 18, 2025, the parties held a telephone conference where counsel for 9 Plaintiff indicated that they would be seeking leave to amend the operative complaint based upon 10 certain circumstances associated with its filing. 11 5. Federal Rule of Civil Procedure 6(b) and Local Rule IA 6-1 impose a good cause 12 standard to extend the deadline file a response to the Motion to Dismiss. “‘Good cause’ is a non- 13 rigorous standard that has been construed broadly across procedural and statutory contexts.” 14 Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1259 (9th Cir. 2010).

15 6. Good cause exists to extend the deadline for Plaintiff to file a response to the 16 Motion to Dismiss based upon the representation by Plaintiff’s counsel that they intend to seek 17 leave to amend the complaint. While LVMPD Defendants neither stipulate to the amendment of 18 the Complaint, nor waive their rights associated with the pending Motion to Dismiss, allowing 19 Plaintiff to seek leave from the Court before responding to the Motion will conserve the 20 expenditure of fees and judicial economy in the event that the Court permits amendment. 21 / / / 22 / / / 23 / / /

24 / / / 1 DATED this 23rd day of June, 2025. 2 || KAEMPFER CROWELL PAUL PADDA LAW By: _/s/ Lyssa S. Anderson By: _/s/ Patrick J. Driscoll 4 LYSSA S. ANDERSON (5781) PAUL S. PADDA (10417) KRISTOPHER J. KALKOWSKI (14892) RAVI CHANDERRAJ (8400) 5 TRAVIS C. STUDDARD (16454) 4560 South Decatur Blvd., #300 1980 Festival Plaza Drive, # 650 Las Vegas, NV 89103 6 Las Vegas, Nevada 89135 ,

7 Attorneys for Defendant ~ and a Pegas Merep olitan Police ANTONIO M. ROMANUCCI 8 P (Admitted PHV) PATRICK DRISCOLL 9 (Admitted PHV) 321 N. Clark Street, Suite 900 10 Chicago, IL 60654 11 Attorneys for Plaintiff 12 13 ORDER 14 IT IS SO ORDERED. 15 16 La CHIEF UNITED STATES DISTRICT JUDGE 17 Dated:__June 24,2025 18 19 20 21 22 23 24 CROWELL Festival Plaza Drive Suite 650.