District of Nevada, "[t]he failure of an opposing party to file points and authorities in response to any motion shall constitute a consent to the granting of the motion.” Local Rule 7-2(d). 2 . "The failure of an opposing party to file points and authorities in response to any motion shall constitute a consent to the granting of the motion.” Local Rule 7 — 2(d). 3 . In comparison, in a case where the officer’s force was not found to be unreasonable, the Court noted that “ “ ‘on the intrusion of his Fourth Amendment Rights’ ” side of the scale, [the plaintiff] does not allege anything more violent than hard pulling and twisting”. Johnson v. County of Los Angeles, 340 F.3d 787, 792 (9th Cir.2003). 4 . See also Michenfelder v. City of Torrance, 28 Cal.App.3d 202, 104 Cal.Rptr. 501 (1972) (<HOLDING>). The Michenfelder court also criticizes the
holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force holding that expert testimony on what constitutes deadly physical force and whether the use of force was justified should have been excluded holding that  2241a1 requires actual use of force meaning use of such physical force as is sufficient to overcome restrain or injure a person holding the use of deadly force is constitutionally permissible only if the officer has probable cause to believe that the suspect poses a threat of serious physical harm either to the officer or to others holding that the decision of a police officer to preserve public safety and order through use of commands backed by threat of force or actual use of physical force is a matter of discretion