1 CODE COMP

Perry Butters
2 XXXX Vegas Valley Dr #XXX
Las Vegas, NV 89121
3 702-966-XXXX
Plaintiff in Proper Person
4

5 DISTRICT COURT
6 CLARK COUNTY, NEVADA
7
PERRY BUTTERS, )
8 )
Plaintiff, )
9 )
)
10 vs. ) Case No.
)
11 NEVADA TAXICAB AUTHORITY, ) Dept No.
)
12 Defendant. )

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 ¶2. This court has jurisdiction over this action
22 pursuant to NRS 239.011.
23 ¶3. Plaintiff, Perry Butters, a citizen of Clark
24 County is the requester of the withheld records.
25 ¶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.
8 ¶6. Plaintiff has a statutory right to the records
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 (2) Award Plaintiff his costs and reasonable
16 attorney’s fees in this action Pursuant to NRS 239.011.
17 (3) Expedite this lawsuit Pursuant to NRS 239.011.
18

19

20 Dated this July 30, 2007

21 ____________________________
Perry Butters
22 XXXX Vegas Valley Dr #XXX
Las Vegas, NV 89121
23

24

25

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27

28

[Summary of pleading] - 2