Bouari v. United States of America et al

Filing 35

ORDER granting 32 Stipulation to Extend Deadline to Answer 31 Amended Complaint. Dennis Lao and Charles Ro answers due 2/15/2021. Signed by Magistrate Judge Brenda Weksler on 1/6/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:18-cv-00219-JCM-BNW Document 32 Filed 12/31/20 Page 1 of 3
35
01/06/21
2

1
2
3
4
5

SIEGMUND F. FUCHS
Trial Attorney, Torts Branch
D.C. Bar No. 986828
U.S. Department of Justice
Ben Franklin Station
P.O. Box 7146
Washington, D.C. 20044-7146
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

6
Attorney for Defendants
7
UNITED STATES DISTRICT COURT
8
DISTRICT OF NEVADA
9
GHASSAN HOUBOUS BOUARI,

14

)
) Case No: 2:18-cv-00219-JCM-PAL
)
)
)
)
STIPULATION TO EXTEND
)
TIME TO RESPOND TO THE FIRST
)
AMENDED COMPLAINT
)
(First Request)
)

15

Pursuant to Local Rule IA 6-1, the parties hereby stipulate to an extension of time for

10
Plaintiff,
11
12

v.
FBI SA CHARLES RO; FBI SA DENNIS
LAO,

13
Defendants.

16

the Defendants to respond to the First Amended Complaint filed on December 29, 2020. (ECF

17

31). This is the first request respecting the subject deadline.

18

The current deadline to respond to the First Amended Complaint is January 12, 2021. See

19

Fed. R. Civ. P. 12(a)(4). The parties had previously consulted on the original complaint in an

20

attempt to limit the issues, claims, and parties before the Court, resulting in the First Amended

21

Complaint. Plaintiff intends to file a separate, but related action against the United States in the

22

coming weeks and to file a notice of related cases. The parties are currently consulting on that

23

separate complaint to again limit the issues and claims before the Court. This request for an

24

extension is for the purpose of allowing the parties to continue to meet and confer and to allow

25

for the briefing on any motions to dismiss in both actions to follow the same schedule.

26

Accordingly, the parties respectfully request that the Defendants’ response to the First

27

Amended Complaint, currently due by January 12, 2021, be extended until February 15, 2021.

28

This stipulation is not sought for purposes of delay or any other improper purpose.

1

Case 2:18-cv-00219-JCM-BNW Document 32 Filed 12/31/20 Page 2 of 3
35
01/06/21
2

1

Respectfully submitted this 31st day of December 2020.

2
3
4
5
6
7
8

/s/ Eugene Iredale
EUGENE IREDALE
Iredale and Yoo, APC
105 West F Street, Fourth Floor
San Diego, California 92101
[phone]
[e-mail]

JEFFREY BOSSERT CLARK
Acting Assistant Attorney General
Civil Division

/s/ Benjamin Durham
BENJAMIN DURHAM
Nevada Bar No. 7684
601 South 10th Street, Suite 101
Las Vegas, Nevada 89101
[phone]
[e-mail]

ANDREA W. MCCARTHY
Senior Trial Counsel
Torts Branch, Civil Division

C. SALVATORE D’ALESSIO, JR.
Acting Director
Torts Branch, Civil Division

13

/s/ Siegmund F. Fuchs
SIEGMUND F. FUCHS
Trial Attorney, Torts Branch
D.C. Bar No. 986828
U.S. Department of Justice
Ben Franklin Station
P.O. Box 7146
Washington, D.C. 20044-7146
[phone]
[e-mail]

14

Attorneys for Defendants

9
10
11

Attorneys for Plaintiff

12

15
16
ORDER
17
18

IT IS SO ORDERED
DATED:

IT IS SO ORDERED:
DATED: 12:44 pm, January 06, 2021

19
20
21

UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
BRENDA WEKSLER
UNITED STATES MAGISTRATE JUDGE

22
23
24
25
26
27
28

2