Kim v. United States of America

Filing 50

ORDER Granting 49 Motion to Extend Time. United States of America answer due 10/25/2017. Signed by Magistrate Judge Carl W. Hoffman on 9/19/17. (Copies have been distributed pursuant to the NEF - ADR)

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JEFFERSON B. SESSIONS III
United States Attorney General
District of Arizona
KATHERINE V. FOSS
Assistant U.S. Attorney
Arizona State Bar No. 029124
J. COLE HERNANDEZ
Assistant US Attorney
Arizona State Bar No. 018802
405 W. Congress Street, Suite 4800
Tucson, Arizona 85701-5040
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Defendant United States

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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Thomas Kim,
Plaintiff,

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v.

DEFENDANT’S FIRST MOTION
FOR EXTENSION OF TIME TO ANSWER
PLAINTIFFS’ AMENDED COMPLAINT

United States of America,
Defendant.

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Case No. 2:16-cv-00778-APG-CWH

CHANG AHN, et al.,

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Case No. 2:17-cv-00133-APG-CWH

Plaintiff,

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v.

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United States of America,

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Defendant.

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Defendant respectfully requests that the Court extend by 30 days the time for Defendant to

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Answer Plaintiffs’ Amended Complaint, which was filed on September 11, 2017.

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Defendant’s first request for additional time to answer the Amended Complaint. With the extension,

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the answer will be due on October 25, 2017.

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This is

Plaintiffs’ Amended Complaint raises new allegations and duties of care, as well as

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identifying different agencies and employees who were purportedly negligent. This extension will

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allow Defendant to coordinate with the Department of Justice as to the discretionary function

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exception to the Federal Tort Claims Act. In addition, Defendant’s counsel has upcoming work

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travel scheduled as well as a number of upcoming dispositive motion deadlines. This extension is

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not sought for the purposes of delay. Defendant has communicated with Plaintiffs’ counsel, and

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said counsel has no objections to this extension of time. A proposed Order is attached herewith.

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Respectfully submitted this 18th day of September, 2017.

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JEFFERSON B. SESSIONS III
United States Attorney General
District of Arizona

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s/ Katherine V. Foss
KATHERINE V. FOSS
J. COLE HERNANDEZ
Special Attorneys to the Attorney General

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IT IS SO ORDERED:

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Defendant’s Motion for Extension of Time to Answer Plaintiff’s Amended Complaint (Doc.
49) is hereby granted. Defendant’s answer shall be due on or before October 25, 2017.

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___________________________________
UNITED STATES MAGISTRATE JUDGE

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DATED:

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9/19/17
_____________________

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CERTIFICATE OF SERVICE

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I hereby certify that on September 18, 2017, I electronically transmitted the attached
document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of
Electronic Filing to the following CM/ECF registrants:
Paul S. Padda, Esq.
PAUL PADDA LAW, PLLC
4240 West Flamingo Road, Suite 220
Las Vegas, Nevada 89103
Kathleen Bliss, Esq.
Jason K. Hicks, Esq.
KATHLEEN BLISS LAW GROUP, PLLC
400 South 4th Street, Suite 500
Las Vegas, Nevada 89101

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s/ Pamela Vavra
Motion for Extension of Time to
Answer Plaintiffs’ Amended Complaint

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