Bouari v. United States of America et al

Filing 39

ORDER granting 38 Stipulation to Extend time to Answer Complaint; Answer(s) due 3/15/2021. Signed by Magistrate Judge Brenda Weksler on 2/16/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:18-cv-00219-JCM-BNW Document 38 Filed 02/08/21 Page 1 of 3
39
02/16/21
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
)
(Second 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 second request respecting the subject deadline.

18

The current deadline to respond to the First Amended Complaint is February 15, 2021.

19

See Order (ECF 35). The parties had previously consulted on the original complaint in an attempt

20

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 still consulting on that separate

23

complaint to again limit the issues and claims before the Court. Plaintiff circulated a proposed

24

pleading two weeks ago and the parties held a lengthy meet and confer. The parties are close to

25

finalizing an agreement. This request for an extension is for the purpose of allowing the parties

26

to continue to meet and confer and to allow for the briefing on any motions to dismiss in both

27

actions to follow the same schedule.

28

1

Case 2:18-cv-00219-JCM-BNW Document 38 Filed 02/08/21 Page 2 of 3
39
02/16/21
2

1

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

2

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

3

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

4

Respectfully submitted this 8th day of February 2021.

5
6
7
8
9
10
11

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

BRIAN M. BOYNTON
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

16

/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]

17

Attorneys for Defendants

12
13
14

Attorneys for Plaintiff

15

18
19
20
21

2/16/2021
DATED:

IT IS SO ORDERED:

22
23
24

UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

25
26
27
28

2