Al Falahi v. United States Citizenship and Immigration Services

Filing 38

ORDER Granting 37 Motion to Extend Time Re: 33 Order. Proposed Joint Pretrial Order due by 5/8/2019. Signed by Judge Jennifer A. Dorsey on 4/30/2019. (Copies have been distributed pursuant to the NEF - ADR)

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JOSEPH H. HUNT
Assistant Attorney General
WILLIAM C. PEACHEY
Director, District Court Section
EDWARD S. WHITE
Senior Litigation Counsel

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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]

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Counsel for the Respondent

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MOHAMMAD AL FALAHI,

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

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

The above named parties, by and through their respective counsel of record, hereby
jointly move for an extention of time to file the joint pretrial order pursuant to LR IA 6-1.
This is the first motion to extend the time to file the joint pretrial order. Good cause

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exists for this extension. The parties are working to reach agreement on issues of fact and law in

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order to reduce what the Court must resolve at trial. In addition, Petitioner is changing counsel

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and this extension of time will allow for an efficient transfer of representation from Petitioner’s
outgoing counsel to his incoming counsel.

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Pursuant to the Court’s March 31, 2019 order, ECF No. 33, the deadline for filing the

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joint pretrial order is May 1, 2019. The Parties respectfully move that the Court extend the

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deadline for filing the joint pretrial order by seven (7) days, up to and including May 8, 2019.

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Date: April 30, 2019

Respectfully submitted,

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/s/ Lauren Kaufman
LAUREN KAUFMAN
Nevada Bar 14677C
American Civil Liberties Union of Nevada
601 South Rancho Dr. Suite B-11
Las Vegas, NV 89106

JOSEPH H. HUNT
Assistant Attorney General

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WILLIAM C. PEACHEY
Director
EDWARD S. WHITE
Senior Litigation Counsel

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

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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

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Counsel for the Petitioner

Counsel for the Respondent

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IT IS SO ORDERED:

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______________________________
UNITED STATES JUDGE
UNITED STATES DISTRICT JUDGE
Dated: April 30, 2019.
DATED: _________________
Dated: April 30, 2019.

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