Song v. Kent et al

Filing 24

ORDER Granting 23 First Stipulation for Extension of Time Re: 22 Motion for Summary Judgment. Responses due by 7/22/2019. Replies due by 8/5/2019. Signed by Chief Judge Gloria M. Navarro on 7/3/2019. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:18-cv-00919-GMN-VCF Document 23 Filed 07/02/19 Page 1 of 2

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NICHOLAS A. TRUTANICH
United States Attorney
District of Nevada
Nevada Bar Number 13644

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MARK E. WOOLF
Assistant United States Attorney
501 Las Vegas Boulevard South, Suite 1100
Las Vegas, Nevada 89101
Telephone: [phone]
Email: [e-mail]

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Attorneys for the United States

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Yali Song,

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Petitioner,
v.

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Jeanne M. Kent, Director, Las Vegas Field
Office of United States Citizenship and
Immigration Services, in her official capacity;
and UNITED STATES CITIZENSHIP AND
IMMIGRATION SERVICES,

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Respondents.

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Case No. 2:18-cv-00919-GMN-VCF
Stipulation to Extend Time
(First Request)

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Pursuant to Local Rule IA 6-1(c), the parties stipulate to extend the briefing schedule in

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this matter for fourteen (14) days. On April 23, 2019, the Court approved the parties’ proposed

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briefing schedule in this matter, ECF No. 19, which provides the following deadlines:

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1. June 15, 2019:

Petitioner will file her Motion for Summary Judgement.

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2. July 6, 2019:

Respondents will file any response to Petitioner’s Motion for

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Summary Judgment in addition to its own Cross-Motion for Summary Judgment.
3. July 20, 2019:

Petitioner will file any response to Respondents’ Cross-Motion for

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Summary Judgment and/or reply to Respondents’ Response to Petitioners Motion for

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Summary Judgment.

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Case 2:18-cv-00919-GMN-VCF Document 23 Filed 07/02/19 Page 2 of 2

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4. August 3, 2019:

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Respondents will file any reply to Petitioner’s Response to

Respondents’ Cross-Motion for Summary Judgment.

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Respondents need additional time to evaluate the arguments set forth in Petitioner’s motion for

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summary judgment, ECF No. 22. The additional time is not sought for purposes of delay or any

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other improper purpose, but to permit for fulsome review of the arguments and potential options

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for resolution. Based on the agreed extension, the new deadlines would be as follows:

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1. July 22, 2019:

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Respondents will file any response to Petitioner’s Motion for

Summary Judgment in addition to its own Cross-Motion for Summary Judgment.

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2. August 5, 2019:

Petitioner will file any response to Respondents’ Cross-Motion for

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Summary Judgment and/or reply to Respondents’ Response to Petitioners Motion for

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Summary Judgment.

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3. August 19, 2019:

Respondents will file any reply to Petitioner’s Response to

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Respondents’ Cross-Motion for Summary Judgment. 1

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Respectfully submitted this 2nd day of July 2019.

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LAW OFFICE OF ALEXANDER VAIL

NICHOLAS A. TRUTANICH
United States Attorney

/s/ Alexander Vail
ALEXANDER VAIL, Esq.
2970 West Sahara Ave.
Las Vegas, Nevada 89102
Attorney for Petitioner

/s/ Mark E. Woolf
MARK E. WOOLF
Assistant United States
Attorney

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Attorneys for Respondents

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IT IS SO ORDERED.

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Dated this ____ day of July, 2019.

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Gloria M. Navarro, Chief Judge
UNITED STATES DISTRICT COURT

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When submitting the initial stipulated briefing schedule, the parties inadvertently submitted dates that all fall on
Saturdays. Thus, while the extension is calculated 14 days from the current deadlines, because each of the original
dates falls on a Saturday, the new deadlines were moved to the next business day pursuant to Fed. R. Civ. P.
6(a)(1)(C).

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