Saubhayana v. Sessions et al

Filing 31

ORDER Granting 30 Unopposed Motion to Extend Time re 29 Order. Amended Complaint deadline: 4/16/2020. Signed by Magistrate Judge Elayna J. Youchah on 3/4/2020. (Copies have been distributed pursuant to the NEF - MR)

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SYLVIA L. ESPARZA, ESQ. NV #8444
Law Office of Sylvia L. Esparza
3340 Pepper Lane, Suite 105
Las Vegas, Nevada 89120
[phone]
Fax [phone]
[e-mail]
Counsel for Plaintiff,
Sathirawat Saubhayana
U.S. DISTRICT COURT
DISTRICT OF NEVADA
LAS VEGAS, NEVADA

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SATHIRAWAT SAUBHAYANA

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Plaintiff

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vs.

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WILLIAM P. BARR, U.S. Attorney
General, et al.,
Defendants

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***
)…CASE NO. 2:17-cv-02655-JAD-GWF
)…Agency No. 087 026 142
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) UNOPPOSED MOTION TO EXTEND
) TIME TO AMEND COMPLAINT
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Plaintiff, Sathirawat Saubhayana, through his Counsel hereby moves to extend the time

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for the filing of the amended complaint until April 16, 2020. This is the second extension of

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time sought in this action with respect to the Defendants’ motion to dismiss. The current filing

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deadline is March 12, 2020. The requested extension of time is based on the following:

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1. This is a challenge to U.S. Citizenship and Immigration Services’ (“USCIS”)

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decision to deny Plaintiff’s application for naturalization. See 8 U.S.C. §1241(c).

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2. Undersigned counsel requires additional time to file the amended complaint. Counsel

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has various upcoming deadlines which require substantial preparation:

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March 6, 2020

9th Circuit Reply Brief

March 11, 2020

9th Circuit Opening Brief

March 12, 2020

9th Circuit Reply Brief

March 12, 2020

District Court Complaint

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March 12, 2020

Response to Motion with 9th Circuit

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March 16, 2020

9th Circuit Reply Brief

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March 19, 2020

9th Circuit Reply Brief

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March 23-24, 2020

Attend and prepare for Oral Argument in San
Francisco, California

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March 25, 2020

9th Circuit Opening Brief

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March 31, 2020

Merits Hearing

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April 1, 2020

Merits Hearing

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April 6, 2020

Merits Hearing

April 9, 2020

Merits Hearing

April 15, 2020

Merits Hearing

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3. Defendants, through counsel, indicated that they do not oppose this motion for an

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extension of time, by email on March 2, 2020. To that end, Plaintiff requests an

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additional 45 days to respond to the motion to dismiss, until April 16, 2020.

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Respectfully submitted,

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/s/ Sylvia L. Esparza__
Sylvia L. Esparza, Esq.
Attorney for Plaintiff

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IT IS SO ORDERED.

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_________________________________
UNITED STATES MAGISTRATE JUDGE

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Dated: March 4, 2020