Tkacz v. Johnson et al

Filing 28

ORDER Granting 27 Stipulation to Continue Hearing Date re 15 and 17 Motions for Summary Judgment and 21 Motion to Amend Complaint. Motion Hearing reset for 10/1/2015 at 10:00 AM in LV Courtroom 7C before Judge Richard F. Boulware II. Signed by Judge Richard F. Boulware, II on 8/20/2015. (Copies have been distributed pursuant to the NEF - DC)

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BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
U.S. Department of Justice
Civil Division
JOHN S. HOGAN
Assistant Director
SAMUEL P. GO
Senior Litigation Counsel
Office of Immigration Litigation
P.O. Box 878, Ben Franklin Station
Washington, DC 20044
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
JESSICA LYNN TKACZ,

)
) Case No. 2:14-cv-00092-RFB-CWH
Plaintiff,
)
)
vs.
) JOINT STIPULATION TO CONTINUE THE
)
HEARING DATE FOR CROSS-MOTIONS
JEH JOHNSON, Secretary, U.S. Department )
FOR SUMMARY JUDGMENT AND
of Homeland Security; JEANNE KENT 1,
)
PLAINTIFF’S MOTION TO AMEND
Field Office Director, United States
)
Citizenship and Immigration Services
)
[Proposed Order Filed Concurrently]
(“USCIS”) Las Vegas Field Office; DANIEL )
G. BOGDEN, U.S. Attorney, Nevada,
)
)
Defendants.
)
)

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Pursuant to Federal Rule of Civil Procedure 25(d), Jeanne Kent, Field Office Director, USCIS Las
Vegas Field Office, is substituted for her predecessor.

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JOINT STIPULATION TO CONTINUE THE HEARING DATE FOR CROSS-MOTIONS

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FOR SUMMARY JUDGMENT AND PLAINTIFF’S MOTION TO AMEND

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IT IS HEREBY STIPULATED that the hearing date on the parties’ Cross-Motions for

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Summary Judgment and Plaintiff’s Motion to Amend Complaint be continued from August 27, 2015 to

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September 24, 2015 or September 25, 2015. Defendant’s counsel, Mr. Samuel Go, has a scheduling

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conflict with the August 27, 2015 hearing date. On August 17, 2015, Mr. Go contacted Mr.

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Constantinos Gus Fountas, Plaintiff’s counsel, asking Mr. Fountas if he would stipulate to continue the

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August 27, 2015 hearing to a later date. Mr. Fountas agreed to continue the hearing date as requested,

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and the parties thus stipulate to continue the hearing date on the parties’ Cross-Motions for Summary

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Judgment and Plaintiff’s Motion to Amend Complaint from August 27, 2015 to September 24, 2015 or

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September 25, 2015. Alternatively, in the event the Court is not available on the proposed dates, the

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parties are amenable to continuing the hearing date to September 22, 2015; September 23, 2015;

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September 29, 2015; or October 1, 2015.

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Dated: August 18, 2015

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Respectfully submitted,

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s\ Samuel P. Go
SAMUEL P. GO
Senior Litigation Counsel
United States Department of Justice
Civil Division
Office of Immigration Litigation
P.O. Box 878, Ben Franklin Station
Washington, DC 20530
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorney for Defendants

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Dated: August 18, 2015

s\Constantinos Gus Fountas (with permission)
CONSTANTINOS GUS FOUNTAS
3340 Pepper Ln. Ste. 103
Las Vegas, NV 89120
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Plaintiff

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CERTIFICATE OF SERVICE

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I hereby certify that a copy of the foregoing JOINT STIPULATION TO CONTINUE THE
HEARING DATE FOR CROSS-MOTIONS FOR SUMMARY JUDGMENT AND PLAINTIFF’S
MOTION TO AMEND was served to the following individuals on this date and by the below method
of service:
Electronic Case Filing:
Constantinos Gus Fountas
Fountas & Associates
3340 Pepper Ln., Ste. 103
Las Vegas, NV 89120

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Dated this 18th day of August 2015.
/s/ Samuel P. Go
SAMUEL P. GO
Senior Litigation Counsel

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
JESSICA LYNN TKACZ,

)
) Case No. 2:14-cv-00092-RFB-CWH
Plaintiff,
)
)
vs.
)
ORDER GRANTING JOINT
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STIPULATION TO CONTINUE THE
JEH JOHNSON, Secretary, U.S. Department )
HEARING DATE FOR CROSS-MOTIONS
of Homeland Security; JEANNE KENT, Field )
FOR SUMMARY JUDGMENT AND
Office Director, United States Citizenship and )
PLAINTIFF’S MOTION TO AMEND
Immigration Services (“USCIS”) Las Vegas )
Field Office; DANIEL G. BOGDEN, U.S.
)
Attorney, Nevada,
)
)
Defendants.
)
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Pursuant to joint stipulation, IT IS HEREBY ORDERED that the hearing date on the parties’
Cross-Motions for Summary Judgment and Plaintiff’s Motion to Amend Complaint be continued
from August 27, 2015 to October 1, 2015 at 10:00 AM in LV Courtroom 7C.

DATED: August 20th, 2015.
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HON. RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE