QUESTION: Can a Complaint be considered a Responsive Pleading, when it's filed after the Answer?
Re NV EVICTIONS: Landlord serves Notice -> Tenant files Answer -> Landlord files Complaint -> Hearing.
SCENARIO: Tenant files same Answer/Argument every time. Landlord fails to appear or moves for Dismissal, Judge shops, & tries again - rather than rebut. We've been through this 5 times.
Can we argue averment under NRCP 8(d) & maybe estoppel?