1 Lawrence J. Semenza, III, Esq., Bar No. 7174 Email: ljs@semenzarickard.com 2 Katie L. Cannata, Esq. Bar No. 14848 Email: klc@semenzarickard.com 3 SEMENZA RICKARD LAW 10161 Park Run Dr., Ste. 150 4 Las Vegas, Nevada 89145 5 Telephone: (702) 835-6803 Facsimile: (702) 920-8669 6 Attorneys for Defendant Las Vegas Metropolitan Police Department 7
8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 RICHARD LOPEZ, a single man, Case No.: 2:25-cv-02434-GMN-MDC
11 Plaintiff, EMERGENCY MOTION TO EXTEND TIME FOR DEFENDANT LAS 12 vs. VEGAS METROPOLITAN POLICE DEPARTMENT TO RESPOND TO 13 THE RIDGES COMMUNITY ASSOCIATION, PLAINTIFF'S COMPLAINT 14 a Nevada Non-Profit Corporation; HOWARD HUGHES PROPERTIES, INC., a Nevada (First Request) 15 Corporation; PRIME COMMUNITY MANAGEMENT LLC, a Nevada Limited 16 Liability Company; MONTE MILLER, an individual; BARBARA VENEZIA, an 17 individual; TYLER BRADY, an individual; 18 APRIL PARSONS, an individual; SALLY ARNOLD, an individual; KIRBY GRUCHOW, 19 JR., a single man; LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a 20 political subdivision of the State of Nevada; CLARK COUNTY DISTRICT ATTORNEY’S 21 OFFICE (AGNES BOTHELHO, ESQ.), a 22 political subdivision of the State of Nevada and Clark County Board of Commissioners; AND 23 JUDGE ERIC GOODMAN, a married man,
24 Defendants.
26 Defendant Las Vegas Metropolitan Police Department ("LVMPD"), by and through its 27 attorneys of record, hereby moves for an extension of time in which to respond to Plaintiff Richard 1 This Motion is based upon the following Memorandum of Points and Authorities, the papers 2 and pleadings on file herein and any oral argument the Court wishes to entertain. 3 Dated this 31st day of December 2025. 4 SEMENZA RICKARD LAW 5 /s/ Katie L. Cannata 6 Lawrence J. Semenza, III, Esq., Bar No. 7174 Katie L. Cannata, Esq. Bar No. 14848 7 10161 Park Run Drive, Ste. 150 8 Las Vegas, Nevada 89145 Attorneys for Defendant Las Vegas Metropolitan 9 Police Department
27 1 DECLARATION OF KATIE L. CANNATA, ESQ. IN SUPPORT OF EMERGENCY MOTION TO EXTEND TIME FOR DEFENDANT LAS VEGAS METROPOLITAN 2 POLICE DEPARTMENT TO RESPOND TO PLAINTIFF'S COMPLAINT (First Request) 3
4 I, KATIE L. CANNATA, state and declare as follows: 5 1. I am a Senior Associate with Semenza Rickard Law, counsel for Defendant Las 6 Vegas Metropolitan Police Department ("LVMPD"). I make the following Declaration in support 7 of the instant Emergency Motion to Extend Time for LVMPD to Respond to Plaintiff Richard 8 Lopez’s ("Plaintiff") Complaint (First Request) (the "Motion"). I have personal knowledge of the 9 facts contained in this Declaration and if called to do so, would testify competently thereto. 10 2. On or about December 30, 2025, my law firm was retained on this matter by 11 LVMPD. That same day, my law firm was informed that LVMPD had been served with the 12 Summons and Complaint on December 10, 2025 – thereby presumably making its responsive 13 pleading due on or before December 31, 2025, i.e. one day following counsel's retention. Upon 14 learning of the December 31, 2025 deadline, my law firm immediately began preparing the instant 15 Motion. 16 3. Given my firm's recent retention, additional time is required to, among other things, 17 (1) review Plaintiff's claims, (2) analyze whether Plaintiff’s claims were timely brought within the 18 applicable statute of limitations period(s) (among other things), (3) review the underlying case file, 19 and (4) prepare a responsive pleading. As of the date of this declaration, my law firm is actively 20 working to accomplish the foregoing. I believe that the requested two-week extension will provide 21 my firm with sufficient time to perform these necessary tasks. 22 4. Considering the current deadline for LMVPD to file a responsive pleading (i.e. 23 December 31, 2025), the instant Motion is brought on an emergency basis. The nature of the 24 emergency is straightforward: to avoid an attempt by Plaintiff to default LVMPD, an extension of 25 the responsive pleading deadline is necessary. As set forth in the Motion, LVMPD's failure to 26 respond to Plaintiff's Complaint on or before the deadline was justified. Among other reasons, my 27 law firm was retained the day before the foregoing responsive pleading was due. In addition, good 1 extension of the responsive pleading deadline will not impose unreasonable delays or prejudice 2 Plaintiff. Rather, a brief extension will ensure that LVMPD has a fair opportunity to respond to 3 Plaintiff's claims. Thus, to avoid a future default against LVMPD, I respectfully request that this 4 Motion be heard on an emergency basis pursuant to LR 7-4. 5 5. The instant Motion is not made to delay proceedings or for any improper purpose. 6 The parties affected by this Motion are as follows: 7 Richard Lopez 101 Convention Center Drive, Suite 1005 8 Las Vegas, Nevada, 89109 rick_lopez_fwd@yahoo.com 9 6. A filed copy of this Motion is being mailed to Plaintiff at the address identified 10 above on December 31, 2025. My firm is also serving a copy of this Motion to the e-mail address 11 registered for e-service of filings in this matter, i.e. rick_lopez_fwd@yahoo.com. 12 I declare under penalty of perjury under the laws of the State of Nevada that the foregoing 13 is true and correct. 14 DATED this 31st day of December, 2025 15 /s/ Katie L. Cannata 16 KATIE CANNATA 17
27 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. BACKGROUND 3 A. Plaintiff's Allegations 4 According to the Complaint, Plaintiff was previously elected to serve as a board member of 5 The Ridges Community Association (the “HOA”). (See ECF No. 2.) Thereafter, Plaintiff contends 6 that he purportedly engaged in whistleblowing activities regarding the HOA's alleged financial 7 misconduct – and was thereby subject to retaliatory and/or discriminatory actions by the HOA, 8 Howard Hughes Properties, Inc., Prime Community Management, LLC, certain affiliated 9 individuals and the Las Vegas Metropolitan Police Department ("LVMPD"). (Id.) Among other 10 things, Plaintiff appears to allege that LVMPD colluded with other named defendants to bring DUI 11 charges and a second criminal action against him. (Id.) Plaintiff further alleges that LVMPD failed 12 to adequately investigate these and other criminal allegations against him. (Id.) 13 B. Pertinent Procedural Background 14 Plaintiff filed his Complaint on December 9, 2025. (ECF No. 2.) Thereafter, on December 15 10, 2025, LVMPD was served with the Summons and Complaint. (ECF No. 7.) 16 On or about December 30, 2025, Semenza Rickard Law was retained on behalf of LVMPD. 17 (Decl., ¶ 2.) Upon being retained, counsel learned that LVMPD had been served with the Summons 18 and Complaint on December 10, 2025 – thereby presumably making its responsive pleading due 19 on or before December 31, 2025, i.e. one day following counsel's retention. (Id.) 20 Considering that counsel was only recently retained in this matter, LVMPD hereby 21 respectfully requests that the Court grant an extension of two (2) weeks in which to file a responsive 22 pleading to Plaintiff's Complaint. The foregoing extension will ensure that LVMPD's counsel has 23 sufficient time to review the underlying case file, as well as Plaintiff's claims, prior to filing a 24 responsive pleading in this action. For these reasons, and those discussed below, good cause exists 25 to extend the responsive pleading deadline to January 14, 2026. 26 /// 27 /// 1 II. ARGUMENT 2 A. Good Cause Exists to Grant LVMPD a Two-Week Extension to Respond to the Complaint 3 Pursuant to Federal Rule of Civil Procedure
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1 Lawrence J. Semenza, III, Esq., Bar No. 7174 Email: ljs@semenzarickard.com 2 Katie L. Cannata, Esq. Bar No. 14848 Email: klc@semenzarickard.com 3 SEMENZA RICKARD LAW 10161 Park Run Dr., Ste. 150 4 Las Vegas, Nevada 89145 5 Telephone: (702) 835-6803 Facsimile: (702) 920-8669 6 Attorneys for Defendant Las Vegas Metropolitan Police Department 7
8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 RICHARD LOPEZ, a single man, Case No.: 2:25-cv-02434-GMN-MDC
11 Plaintiff, EMERGENCY MOTION TO EXTEND TIME FOR DEFENDANT LAS 12 vs. VEGAS METROPOLITAN POLICE DEPARTMENT TO RESPOND TO 13 THE RIDGES COMMUNITY ASSOCIATION, PLAINTIFF'S COMPLAINT 14 a Nevada Non-Profit Corporation; HOWARD HUGHES PROPERTIES, INC., a Nevada (First Request) 15 Corporation; PRIME COMMUNITY MANAGEMENT LLC, a Nevada Limited 16 Liability Company; MONTE MILLER, an individual; BARBARA VENEZIA, an 17 individual; TYLER BRADY, an individual; 18 APRIL PARSONS, an individual; SALLY ARNOLD, an individual; KIRBY GRUCHOW, 19 JR., a single man; LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a 20 political subdivision of the State of Nevada; CLARK COUNTY DISTRICT ATTORNEY’S 21 OFFICE (AGNES BOTHELHO, ESQ.), a 22 political subdivision of the State of Nevada and Clark County Board of Commissioners; AND 23 JUDGE ERIC GOODMAN, a married man,
24 Defendants.
26 Defendant Las Vegas Metropolitan Police Department ("LVMPD"), by and through its 27 attorneys of record, hereby moves for an extension of time in which to respond to Plaintiff Richard 1 This Motion is based upon the following Memorandum of Points and Authorities, the papers 2 and pleadings on file herein and any oral argument the Court wishes to entertain. 3 Dated this 31st day of December 2025. 4 SEMENZA RICKARD LAW 5 /s/ Katie L. Cannata 6 Lawrence J. Semenza, III, Esq., Bar No. 7174 Katie L. Cannata, Esq. Bar No. 14848 7 10161 Park Run Drive, Ste. 150 8 Las Vegas, Nevada 89145 Attorneys for Defendant Las Vegas Metropolitan 9 Police Department
27 1 DECLARATION OF KATIE L. CANNATA, ESQ. IN SUPPORT OF EMERGENCY MOTION TO EXTEND TIME FOR DEFENDANT LAS VEGAS METROPOLITAN 2 POLICE DEPARTMENT TO RESPOND TO PLAINTIFF'S COMPLAINT (First Request) 3
4 I, KATIE L. CANNATA, state and declare as follows: 5 1. I am a Senior Associate with Semenza Rickard Law, counsel for Defendant Las 6 Vegas Metropolitan Police Department ("LVMPD"). I make the following Declaration in support 7 of the instant Emergency Motion to Extend Time for LVMPD to Respond to Plaintiff Richard 8 Lopez’s ("Plaintiff") Complaint (First Request) (the "Motion"). I have personal knowledge of the 9 facts contained in this Declaration and if called to do so, would testify competently thereto. 10 2. On or about December 30, 2025, my law firm was retained on this matter by 11 LVMPD. That same day, my law firm was informed that LVMPD had been served with the 12 Summons and Complaint on December 10, 2025 – thereby presumably making its responsive 13 pleading due on or before December 31, 2025, i.e. one day following counsel's retention. Upon 14 learning of the December 31, 2025 deadline, my law firm immediately began preparing the instant 15 Motion. 16 3. Given my firm's recent retention, additional time is required to, among other things, 17 (1) review Plaintiff's claims, (2) analyze whether Plaintiff’s claims were timely brought within the 18 applicable statute of limitations period(s) (among other things), (3) review the underlying case file, 19 and (4) prepare a responsive pleading. As of the date of this declaration, my law firm is actively 20 working to accomplish the foregoing. I believe that the requested two-week extension will provide 21 my firm with sufficient time to perform these necessary tasks. 22 4. Considering the current deadline for LMVPD to file a responsive pleading (i.e. 23 December 31, 2025), the instant Motion is brought on an emergency basis. The nature of the 24 emergency is straightforward: to avoid an attempt by Plaintiff to default LVMPD, an extension of 25 the responsive pleading deadline is necessary. As set forth in the Motion, LVMPD's failure to 26 respond to Plaintiff's Complaint on or before the deadline was justified. Among other reasons, my 27 law firm was retained the day before the foregoing responsive pleading was due. In addition, good 1 extension of the responsive pleading deadline will not impose unreasonable delays or prejudice 2 Plaintiff. Rather, a brief extension will ensure that LVMPD has a fair opportunity to respond to 3 Plaintiff's claims. Thus, to avoid a future default against LVMPD, I respectfully request that this 4 Motion be heard on an emergency basis pursuant to LR 7-4. 5 5. The instant Motion is not made to delay proceedings or for any improper purpose. 6 The parties affected by this Motion are as follows: 7 Richard Lopez 101 Convention Center Drive, Suite 1005 8 Las Vegas, Nevada, 89109 rick_lopez_fwd@yahoo.com 9 6. A filed copy of this Motion is being mailed to Plaintiff at the address identified 10 above on December 31, 2025. My firm is also serving a copy of this Motion to the e-mail address 11 registered for e-service of filings in this matter, i.e. rick_lopez_fwd@yahoo.com. 12 I declare under penalty of perjury under the laws of the State of Nevada that the foregoing 13 is true and correct. 14 DATED this 31st day of December, 2025 15 /s/ Katie L. Cannata 16 KATIE CANNATA 17
27 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. BACKGROUND 3 A. Plaintiff's Allegations 4 According to the Complaint, Plaintiff was previously elected to serve as a board member of 5 The Ridges Community Association (the “HOA”). (See ECF No. 2.) Thereafter, Plaintiff contends 6 that he purportedly engaged in whistleblowing activities regarding the HOA's alleged financial 7 misconduct – and was thereby subject to retaliatory and/or discriminatory actions by the HOA, 8 Howard Hughes Properties, Inc., Prime Community Management, LLC, certain affiliated 9 individuals and the Las Vegas Metropolitan Police Department ("LVMPD"). (Id.) Among other 10 things, Plaintiff appears to allege that LVMPD colluded with other named defendants to bring DUI 11 charges and a second criminal action against him. (Id.) Plaintiff further alleges that LVMPD failed 12 to adequately investigate these and other criminal allegations against him. (Id.) 13 B. Pertinent Procedural Background 14 Plaintiff filed his Complaint on December 9, 2025. (ECF No. 2.) Thereafter, on December 15 10, 2025, LVMPD was served with the Summons and Complaint. (ECF No. 7.) 16 On or about December 30, 2025, Semenza Rickard Law was retained on behalf of LVMPD. 17 (Decl., ¶ 2.) Upon being retained, counsel learned that LVMPD had been served with the Summons 18 and Complaint on December 10, 2025 – thereby presumably making its responsive pleading due 19 on or before December 31, 2025, i.e. one day following counsel's retention. (Id.) 20 Considering that counsel was only recently retained in this matter, LVMPD hereby 21 respectfully requests that the Court grant an extension of two (2) weeks in which to file a responsive 22 pleading to Plaintiff's Complaint. The foregoing extension will ensure that LVMPD's counsel has 23 sufficient time to review the underlying case file, as well as Plaintiff's claims, prior to filing a 24 responsive pleading in this action. For these reasons, and those discussed below, good cause exists 25 to extend the responsive pleading deadline to January 14, 2026. 26 /// 27 /// 1 II. ARGUMENT 2 A. Good Cause Exists to Grant LVMPD a Two-Week Extension to Respond to the Complaint 3 Pursuant to Federal Rule of Civil Procedure 6(b), a party may seek an extension of time 4 upon a showing of “good cause” for acts that “must be done within a specified time.” Fed. R. Civ. 5 Pro. 6(b)(1). These requests may be made “with or without motion… before the original time or 6 its extension expires[.]” Fed. R. Civ. Pro. 6(b)(1); see also LR IA 6-1(a). 7 Generally, a good cause analysis turns on whether the subject deadline cannot reasonably 8 be met despite the exercise of diligence. See e.g., Johnson v. Mammoth Recreations, Inc., 975 F.2d 9 604, 609 (9th Cir. 1992). Importantly, it is well within the Court's discretion to grant the requested 10 extension. Tindall v. First Solar Inc., 892 F.3d 1043, 1048 (9th Cir. 2018) (the district court may 11 grant motions for an extension of time upon a finding of good cause); see also Amateur Athelitic 12 Union of United States, Inc. v. Williams, No. 223CV00864ARTBNW, 2023 WL 5170505, at *2 13 (D. Nev. Aug. 10, 2023) (finding good cause to grant an extension to file an answer to a complaint). 14 “[R]equests for extensions of time made before the applicable deadline has passed should ‘normally 15 ... be granted in the absence of bad faith on the part of the party seeking relief or prejudice to the 16 adverse party.’” Id. (citing 4B Wright & Miller, Federal Practice and Procedure § 1165 (3d ed. 17 2004)). 18 If the foregoing standard is met, such requests are typically granted. See Kerner v. U.S. 19 Veteran Affs. Med. Ctr., No. 2:23-CV-01872-JAD-MDC, 2025 WL 315146, at *2 (D. Nev. Jan. 28, 20 2025). 21 Here, good cause clearly exists to grant LVMPD's request for a two-week extension in 22 which to file its responsive pleading, up to and including January 14, 2026. As set forth above, 23 counsel for LVMPD was only recently retained in this matter. (Id. at ¶ 2.) Given their recent 24 retention, counsel requires additional time to (1) review Plaintiff's claims, (2) analyze whether 25 Plaintiff’s claims were timely brought within the applicable statute of limitations period(s) (among 26 other things), (3) review the underlying case file, and (4) prepare a responsive pleading. (Id. at ¶ 27 4.) Counsel believes that the requested two-week extension will provide sufficient time to perform | || these necessary tasks. (/d. at ¢ 5.) Moreover, and as established herein, the requested extension 2 ||is not the result of undue delay and will not prejudice Plaintiff at these early stages of the 3 || proceedings. 4 Accordingly, good cause exists to extend the deadline for LVMPD's responsive pleading 5 || deadline to January 16, 2026. 6 || Ul. CONCLUSION 7 Based upon the foregoing, LVMPD respectfully requests that the Court grant the instant 8 || Motion and extend the deadline in which to respond to Plaintiff's Complaint to January 16, 2026. 9 Dated this 31st day of December, 2025. 10 SEMENZA RICKARD LAW 11 /s/_Katie L. Cannata on 12 Lawrence J. Semenza, III, Esq., Bar No. 7174 B Katie L. Cannata, Esq. Bar No. 14848 10161 Park Run Drive, Ste. 150 q 14 Las Vegas, Nevada 89145
2 15 Attorneys for Defendant Las Vegas Metropolitan > 8 6 Police Department 7 IT IS SO ORDERED. For good cause shown, | GRANT the motion nunc pro tunc.
19 oo x 20 if “Hon. Maximfidno L). Couvilfeér Il 21 LY United States Magistratewudge Dated:1-9526 22 7, 23 24 25 26 27 28
1 CERTIFICATE OF SERVICE
2 I am employed by the law firm of Semenza Rickard Law in Clark County, Nevada. I am over the age of 18 and not a party to this action. The business address is 10161 Park Run Drive, 3 Suite 150, Las Vegas, Nevada 89145.
4 On the 31st day of December 2025, I served the document(s), described as: 5 EMERGENCY MOTION TO EXTEND TIME FOR DEFENDANT LAS VEGAS 6 METROPOLITAN POLICE DEPARTMENT TO RESPOND TO PLAINTIFF'S COMPLAINT 7
8 by sending an original a true copy
9 a. via CM/ECF System (You must attach the “Notice of Electronic Filing”, or list all persons and addresses and attach additional paper if necessary) 10 Richard Lopez, rick_lopez_fwd@yahoo.com 11 Plaintiff Pro Se 12 Freeman Mathis & Gary 13 James Lovett, II, james.lovett@fmglaw.com Derek R Noack, derek.noack@fmglaw.com 14 Attorneys for Defendants Sally Arnold, Tyler Brady, Monte Miller, April Parsons, Barbara Venezia, Prime Community Management LLC and The Ridges Community Association 15
16 Brownstein Hyatt Farber Schreck, LLP Patrick J Reilly, preilly@bhfs.com 17 Attorneys for Defendant Howard Hughes Properties Inc.
18 b. BY U.S. MAIL. I deposited such envelope in the mail at Las Vegas, Nevada. The envelope(s) were mailed with postage thereon fully prepaid. I am readily familiar with Semenza 19 Rickard Law's practice of collection and processing correspondence for mailing. Under that 20 practice, documents are deposited with the U.S. Postal Service on the same day, which is stated in the proof of service, with postage fully prepaid at Las Vegas, Nevada in the ordinary course of 21 business. I am aware that on motion of party served, service is presumed invalid if the postal cancellation date or postage meter date is more than one day after the date stated in this proof of 22 service.
23 Richard Lopez 24 101 Convention Center Drive, Suite 1005 Las Vegas, Nevada, 89109 25 Plaintiff Pro Se
26 c. BY PERSONAL SERVICE.
27 /// 1 d. BY DIRECT EMAIL.
2 Richard Lopez, rick_lopez_fwd@yahoo.com Plaintiff Pro Se 3 e. BY FACSIMILE TRANSMISSION. 4
5 I declare under penalty of perjury that the foregoing is true and correct.
6 /s/ Olivia A. Kelly 7 An Employee of Semenza Rickard Law 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27