Solorzano et al v. Campagnolo et al

Filing 16

ORDER granting #14 Stipulation for Extension of Time to Respond to Plaintiffs Complaint (First Request). Defendant's answer due 6/15/2024. Signed by Magistrate Judge Daniel J. Albregts on 3/26/2024. (Copies have been distributed pursuant to the NEF - CAH)

Case 2:24-cv-00240-GMN-DJA Document 15 Filed 03/26/24 Page 1 of 4

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JASON M. FRIERSON
United States Attorney
District of Nevada
Nevada Bar No. 7709
ANN WILKINSON
Assistant United States Attorney
Nevada Bar No. 5826
400 South Virginia Street, Suite 900
Reno, Nevada 89501
Telephone: [phone]
[e-mail]
Attorneys for Defendants
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Isabel Solorzano and
Ronaldo Yersay Palacos Cardona,
v.

GMN-DJA
Case No. 2:24-cv-00240-JCM-DJA

Plaintiffs,

DONNA P. CAMPAGNOLO, Director,
California Service Center, U.S. Citizenship
and Immigration Services, in her official
capacity as well as her successors and assign;

Stipulation and Order for Extension of
Time to Respond to Plaintiffs’
Complaint (First Request)

ALEJANDRO MAYORKAS, Secretary,
Department of Homeland Security, in his
official capacity as well as his successors and
assigns;
UR MENDOZA JADDOU, Director, U.S.
Citizenship and Immigration Services, in her
official capacity as well as her successor and
assigns;
ANTONY BLINKEN, Secretary of State, in
his official capacity as well as his successor
and assigns;
PHILLIP SLATTERY, Director, National
Visa Center, U.S. Department of State, in his
official capacity as well as his successors and
assigns; and
RICHARD C. VISEK, Acting Legal
Advisor, U.S. Department of State, in his
official capacity as well as his successors and
assigns,
Defendants.
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Case 2:24-cv-00240-GMN-DJA Document 15 Filed 03/26/24 Page 2 of 4

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Plaintiffs and Defendants, through their undersigned counsel, stipulate and request

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that the Court approve a 60-day extension of time, from April 15, 2024, to June 15, 2024,

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for Defendants to respond to Plaintiffs’ Complaint, ECF. No. 1. This is the parties’ first

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request for an extension of time.

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

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request additional time to perform an act. The subject of this litigation concerns Plaintiffs’ I-

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129F Petition for Alien Fiancée (“First Petition”). On or about December 28, 2020, Plaintiffs

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submitted to Defendants’ U.S. Citizen and Immigration Services (“USCIS”) their First

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Petition, which was approved by USCIS and then forwarded to National Visa Center

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(“NVC”) and the United States Consulate (“Consulate”) for processing. The First Petition

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was subsequently cancelled, and Plaintiffs were informed that a new I-129F Petition (Second

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Petition) should be submitted. USCIS approved Plaintiffs’ Second Petition on or about

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March 13, 2024, and Plaintiffs are now awaiting processing of the Second Petition by the

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NVC and Consulate. Pending the remaining administrative processing of the Second

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Petition this litigation may become moot.

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Case 2:24-cv-00240-GMN-DJA Document 15 Filed 03/26/24 Page 3 of 4

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Based on these circumstances, the parties request an additional 60-day extension of

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time, from April 15, 2024, to June 15, 2024, for Defendants to file a response to Plaintiffs’

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Complaint, ECF. No. 1. This stipulated request is filed in good faith and not for the purposes

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of undue delay.

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Respectfully submitted this 25th day of March 2024.

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DATED:

March 25, 2024

DATED: March 25, 2024

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QUIROGA LAW OFFICE, PLLC

JASON M. FRIERSON
United States Attorney

/s/ Maria E. Quiroga
MARIA E. QUIROGA

/s/ Ann Wilkinson
ANN WILKINSON
Assistant United States Attorney

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IT IS SO ORDERED:
_______________________________________
DANIEL
ALBREGTS
UNITEDJ.STATES
DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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3/26/2024
DATED: ______________________________

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Case 2:24-cv-00240-GMN-DJA Document 15 Filed 03/26/24 Page 4 of 4

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Certificate of Service
I, Danielle Bleecker, Paralegal Specialist, hereby certifies that on March 25, 2024 I
electronically filed and served the foregoing STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT (First
Request) with the Clerk for the United States District Court for the District of Nevada
using the CM/ECF system; and served the same using the Court’s CM/ECF system to:
Maria E. Quiroga, Esq.
QUIROGA LAW OFFICE PLLC
7395 W. Sahara Ave., Suite #103
Las Vegas, NV 89117
Maria.QuirogaLawOffice.com
Attorney for Plaintiffs
Dated this 25th day of March 2024.
/s/ Danielle Bleecker
DANIELLE BLEECKER

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