Felix v. U.S. Department of State, et al

Filing 23

ORDER Granting 22 Motion to Extend Time (First Request) Unopposed re 1 Complaint. Robert Jachim answer due 4/9/2025; Kristi Noem answer due 4/9/2025; Marco Rubio answer due 4/9/2025; Kika Scott answer due 4/9/2025; U.S. Department of State answer due 4/9/2025; U.S. Embassy in Frankfurt, Germany answer due 4/9/2025. Signed by Magistrate Judge Daniel J. Albregts on 3/6/2025. (Copies have been distributed pursuant to the NEF - ALZ)

1
2
3
4
5
6
7
8
9
10
11

YAAKOV M. ROTH
Acting Assistant Attorney General
Civil Division
LAUREN E. FASCETT
Senior Litigation Counsel
MARY L. LARAKERS
Senior Litigation Counsel
U.S. Department of Justice
Civil Division
Office of Immigration Litigation
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Telephone: [phone]
Email: [e-mail]
Counsel for Defendants

12

DISTRICT OF NEVADA

13
Ana Gloria Felix,

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

UNITED STATES DISTRICT COURT

Plaintiff,
v.
United States Department of State, et al.,
Defendants.

Case No. 2:24-cv-00812 -JCM-DJA
Honorable James C. Mahan
ORDER RE:
DEFENDANTS’ UNOPPOSED MOTION
TO EXTEND TIME TO ANSWER
COMPLAINT (First Request)

1

Defendants hereby move for a thirty-day extension of time to answer the complaint

2

(ECF No. 1) until April 9, 2025. This is Defendants’ first request for an extension of time to

3

answer to the complaint. The current answer filing deadline is March 10, 2025 – fourteen days

4

after this Court denied Defendants’ motion to dismiss. See Fed. R. Civ. P. 12(a)(4)(A). The

5

requested extension of time is for good cause and based on the following:

6

1. Plaintiff brings this action seeking to compel the Department of State (DOS) to

7

reissue a decision on her son’s visa application that a consular officer previously

8

refused under the Immigration and Nationality Act (“INA”) § 221(g), 8 U.S.C.

9

§ 1201(g). ECF No. 1, Compl. ¶ 2.

10

2. On July 1, 2024, Defendants moved to dismiss Plaintiff’s complaint (ECF No. 14),

11

and this Court denied Defendants’ motion on February 24, 2025 (ECF No. 19).

12

3. The parties have discussed whether DOS may, in the near future, re-adjudicate the

13

visa at issue in this case and therefore resolve this case without further litigation.

14

Defendants would like more time to explore whether this is possible.

15

4. Plaintiff, through counsel, indicated that she does not oppose this motion for an

16

extension of time. To that end, Defendants request an additional thirty days to answer

17

the complaint, until April 9, 2025.

18
19

YAAKOV M. ROTH
Acting Assistant Attorney General, Civil
Division

20
21

LAUREN E. FASCETT
Senior Litigation Counsel

22
23
24
25
26
27
28

By: /s/ Mary L. Larakers
MARY L. LARAKERS
Senior Litigation Counsel
U.S. Department of Justice, Civil Division
Office of Immigration Litigation
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Tel: [phone]

1

1

Fax: [phone]
[e-mail]

2
3
4
5
6
7
8
9
10
11

ORDER
IT IS SO ORDERED that Defendant's unopposed motion to extend time to answer complaint
(ECF No. 22) is GRANTED. Defendant shall have until April 9, 2025 to respond to the
complaint.
DATED: 3/6/2025
___________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

2