Garcia v. Cohan et al

Filing 14

ORDER Granting 13 Unopposed Motion for Extension of Time. Antony Blinken answer due 12/20/2023; Eric S. Cohan answer due 12/20/2023; Stephanie Syptak-Ramnath answer due 12/20/2023. Signed by Magistrate Judge Cam Ferenbach on 11/14/2023. (Copies have been distributed pursuant to the NEF - RGDG)

1 JASON M. FRIERSON
United States Attorney
2 District of Nevada
Nevada Bar No. 7709
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PATRICK A. ROSE
4 Assistant United States Attorney
Nevada Bar No. 5109
5 501 Las Vegas Blvd. So., Suite 1100
Las Vegas, Nevada 89101
6 [phone]
Patrick [e-mail]
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Attorneys for the Federal Defendants
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Jacqueline Garcia,
Plaintiff,

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Case No: 2:23-cv-00849-CDS-VCF

v.
Eric S. Cohan, Stephanie Syptak-Ramnath,
Antony Blinken,

Unopposed Motion for Extension of
Time
(Fourth Request)

Defendants.

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The Federal Defendants respectfully move for a 30-day extension of time, from

18 November 20, 2023, to December 20, 2023, to file a response to Plaintiff’s Complaint (ECF
19 No. 1). This is the fourth request for an extension of time. Undersigned defense counsel has
20 inquired with Plaintiff’s counsel, who agrees with this request. Indeed, Plaintiff’s counsel
21 would like additional time to confer with his client.
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MEMORANDUM OF POINTS AND AUTHORITIES

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Federal Rule of Civil Procedure 6(b)(1) and Local Rule IA 6-1 allow a party to

24 request additional time to perform an act. In this case, the Federal Defendants request
25 additional time to file a response to the Complaint for the reasons set forth below.
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Without admission or waiver by the parties, the parties continue to assess recent

27 developments at the agency level. Plaintiff’s counsel would like additional time to confer
28 with his client. Defense counsel has a number of pressing matters in other cases including a

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motion for summary judgment due on November 20, 2023, and an upcoming settlement

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conference for which settlement authority must be sought. Additionally, there is the

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prospect of a lapse of congressionally-funded appropriations on November 17, 2023.

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Lapses of appropriations negatively affect the availability of personnel at the USAO, client

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agencies, or both to conduct business.

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This motion is filed in good faith and not for the purposes of undue delay.

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Accordingly, Federal Defendants respectfully request, and Plaintiff’s counsel consents to,

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this extension of time, from November 20, 2023, to December 20, 2023, to file a response

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to Plaintiff’s Complaint.

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Respectfully submitted this 14th day of November 2023.
JASON M. FRIERSON
United States Attorney
/s/ Patrick A. Rose
PATRICK A. ROSE
Assistant United States Attorney

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IT IS SO ORDERED

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UNITED STATES MAGISTRATE JUDGE
11-14-2023
DATED:

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