Perry Butters Vs State Of Nevada
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CODE COMP Perry Butters XXXX Vegas Valley Dr #XXX Las Vegas, NV 89121 702-966-XXXX Plaintiff in Proper Person
4 5
DISTRICT COURT
6
CLARK COUNTY, NEVADA
7
PERRY BUTTERS, 8
Plaintiff, 9 10 11
vs. NEVADA TAXICAB AUTHORITY,
12
Defendant.
) ) ) ) ) ) ) ) ) )
Case No. Dept No.
13 14
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
15
¶1. This is an action under Nevada’s public books and
16
public records open to inspection statute, NRS 239.010, to order
17
the production of a government entity’s records previously
18
requested by Plaintiff pursuant to the above-referenced statute
19
and whose request has been denied by the Defendant government
20
entity.
21 22 23 24 25
¶2. This court has jurisdiction over this action pursuant to NRS 239.011. ¶3. Plaintiff, Perry Butters, a citizen of Clark County is the requester of the withheld records. ¶4. Defendant, Nevada Taxicab Authority, is a
26
government entity of Nevada and is located within Clark County
27
and it has possession of, and control over, the records that
28
Plaintiff seeks.
[Summary of pleading] - 1
1
¶5. On April 15, 2007 the Plaintiff mailed a request
2
to the Defendant for the Annual Reports submitted by all
3
certificate holders pursuant to the provisions of NRS 706.8829
4
for the years 2003, 2004, and 2005. The Plaintiff’s request for
5
records for the years 2003 and 2004 were fulfilled by the
6
Defendant. The Plaintiff’s request for records for the year 2005
7
was denied by the Defendant citing NAC 706.479. ¶6. Plaintiff has a statutory right to the records
8 9
that he seeks.
10
¶7. Therefore, Plaintiff prays that this Court:
11
(1) Order the Defendant to produce the records the
12
Plaintiff seeks for the year 2005 and any records of the same
13
type for any subsequent years that the Plaintiff requests in the
14
future.
15 16 17
(2) Award Plaintiff his costs and reasonable attorney’s fees in this action Pursuant to NRS 239.011. (3) Expedite this lawsuit Pursuant to NRS 239.011.
18 19 20 21 22
Dated this July 30, 2007 ____________________________ Perry Butters XXXX Vegas Valley Dr #XXX Las Vegas, NV 89121
23 24 25 26 27 28
[Summary of pleading] - 2
CODE COMP Perry Butters XXXX Vegas Valley Dr #XXX Las Vegas, NV 89121 702-966-XXXX Plaintiff in Proper Person
4 5
DISTRICT COURT
6
CLARK COUNTY, NEVADA
7
PERRY BUTTERS, 8
Plaintiff, 9 10 11
vs. NEVADA TAXICAB AUTHORITY,
12
Defendant.
) ) ) ) ) ) ) ) ) )
Case No. Dept No.
13 14
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
15
¶1. This is an action under Nevada’s public books and
16
public records open to inspection statute, NRS 239.010, to order
17
the production of a government entity’s records previously
18
requested by Plaintiff pursuant to the above-referenced statute
19
and whose request has been denied by the Defendant government
20
entity.
21 22 23 24 25
¶2. This court has jurisdiction over this action pursuant to NRS 239.011. ¶3. Plaintiff, Perry Butters, a citizen of Clark County is the requester of the withheld records. ¶4. Defendant, Nevada Taxicab Authority, is a
26
government entity of Nevada and is located within Clark County
27
and it has possession of, and control over, the records that
28
Plaintiff seeks.
[Summary of pleading] - 1
1
¶5. On April 15, 2007 the Plaintiff mailed a request
2
to the Defendant for the Annual Reports submitted by all
3
certificate holders pursuant to the provisions of NRS 706.8829
4
for the years 2003, 2004, and 2005. The Plaintiff’s request for
5
records for the years 2003 and 2004 were fulfilled by the
6
Defendant. The Plaintiff’s request for records for the year 2005
7
was denied by the Defendant citing NAC 706.479. ¶6. Plaintiff has a statutory right to the records
8 9
that he seeks.
10
¶7. Therefore, Plaintiff prays that this Court:
11
(1) Order the Defendant to produce the records the
12
Plaintiff seeks for the year 2005 and any records of the same
13
type for any subsequent years that the Plaintiff requests in the
14
future.
15 16 17
(2) Award Plaintiff his costs and reasonable attorney’s fees in this action Pursuant to NRS 239.011. (3) Expedite this lawsuit Pursuant to NRS 239.011.
18 19 20 21 22
Dated this July 30, 2007 ____________________________ Perry Butters XXXX Vegas Valley Dr #XXX Las Vegas, NV 89121
23 24 25 26 27 28
[Summary of pleading] - 2
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