Al Falahi v. United States Citizenship and Immigration Services

Filing 15

ORDER Granting 14 Motion to Extend Time to File Dispositive Motions. IT IS HEREBY ORDERED that dispositive motions must be filed by 1/31/18. Signed by Magistrate Judge Cam Ferenbach on 10/13/17. (Copies have been distributed pursuant to the NEF - ADR) Modified on to correct due date 10/13/2017 (ADR).

1
2
3
4
5

CHAD A. READLER
Acting Assistant Attorney General
WILLIAM C. PEACHEY
Director, District Court Section
EDWARD S. WHITE
Senior Litigation Counsel

10

JOSEPH F. CARILLI, JR.
N.H. Bar Identification No. 15311
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
E-mail: [e-mail]

11

Attorneys for the Respondent

6
7
8
9

12

UNITED STATES DISTRICT COURT

13

DISTRICT OF NEVADA

14
15
16
17
18
19

MOHAMMAD AL FALAHI,

)
)
Petitioner,
)
)
vs.
)
)
UNITED STATES CITIZENSHIP AND
)
IMMIGRATION SERVICES,
)
)
Respondent.
)
____________________________________)

20

Case No.: 2:16-cv-02921-JAD-VCF
JOINT MOTION FOR AN EXTENSION
OF TIME TO FILE DISPOSTIVE
MOTIONS

The above named parties, by and through their respective counsel of record hereby

21

submit this joint motion for an extention of time to file dispostive motions pursuant to LR IA 6-

22

1.

23
24
25
26
27
28

This is the first motion for extension of time to file dispositive motions. Good cause
exists for this extension. On October 6, 2017, Petitioner served a Rule 30(b)(6) deposition
notice, requesting to depose a U.S. Citzenship and Immigration Services (“USCIS”) employee
on the USCIS’ Controlled Application Review and Resolution Process (“CARRP”) and noticed
Respondent of intention to depose the two USCIS employees that interviewed Petitioner about
his application for naturalization. Petitioner plans to ask these USCIS employees questions
1

1

regarding the CARRP. On October 11, 2017, Respondent filed a motion for a protective order to

2

limit discovery into the CARRP. The parties met and conferred but were unable to resolve the

3

discovery dispute. This extension of time will allow the Court time to consider the motion for

4

the protective order and to allow for the parties to complete the depositions prior to submission

5
6
7
8

of dispositive motions.
Pursuant to the Court’s Joint Discovery Plan and Scheduling Order, ECF No. 10, the date
for filing dispositive motions shall not be later than thirty (30) days after the discovery cut-off
date, which in this matter is not later than Wednesday November 22, 2017. ECF No. 10, at 3.

9
The Parties move that the date for filing dispositive motion shall not be later than ninety (90)
10
11
12
13
14

days after the Court rules on the motion for a protective order. The date for the completion of
the depositions shall be within thirty (30) days after the Court rules on the motion for a
protective order. The discovery period will remain open for sole purpose of completing the
depositions.

15
16
17
18
19
20
21
22
23
24
25
26
27
28

2

1
2
3
4
5
6
7
8
9
10
11

Date: October 11, 2017

Respectfully submitted,

/s/ Amy Rose
AMY ROSE
Nevada Bar 12081
American Civil Liberties Union of Nevada
601 South Rancho Dr. Suite B-11
Las Vegas, NV 89106

CHAD A. READLER
Acting Assistant Attorney General
WILLIAM C. PEACHEY
Director
EDWARD S. WHITE
Senior Litigation Counsel

ALEXANDRA CHRYSANTHIS
Nevada Bar 3231
Prudhomme Law Office
633 S 4th St #7
Las Vegas, NV 89101

/s/ Joseph F. Carilli, Jr.
JOSEPH F. CARILLI, JR.
N.H. Bar Identification No. 15311
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044

Counsel for the Petitioner

12
13
14
15
16
17

Counsel for the Respondent

IT IS HEREBY ORDERED that
dispositive motions must be
filed by January 31, 2018.

IT IS SO ORDERED:

18

UNITED STATES MAGISTRATE JUDGE,

19

October 13, 2017
DATED: _________________

20
21
22
23
24
25
26
27
28

3

1
2
3
4
5
6
7
8
9
10
11
12
13

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served via the court’s
electronic case filing system on October 11, 2017, to the counsel for the petitioner:
Amy Rose
Nevada Bar 12081
American Civil Liberties Union of Nevada
601 South Rancho Dr. Suite B-11
Las Vegas, NV 89106
Telephone: [phone]
E-mail: [e-mail]
Alexandra Chrysanthis
Nevada Bar 3231
Prudhomme Law Office
633 S 4th St #7
Las Vegas, NV 89101
Telephone: [phone]
E-mail: [e-mail]

14
15
16
17
18
19
20
21

/s/ Joseph F. Carilli, Jr.
JOSEPH F. CARILLI, JR.
N.H. Bar Identification No. 15311
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
E-mail: [e-mail]

22
23

Attorney for the Respondent

24
25
26
27
28

1