Garza v. Blinken ( 2024 )

1 JUAnSitOedN S Mtat.e Fs RAItEtoRrnSeOyN 2 District of Nevada Nevada Bar Number 7709 3 SKYLER H. PEARSON 4 Assistant United States Attorney 501 Las Vegas Blvd. So., Suite 1100 5 Las Vegas, Nevada 89101 (702) 388-6336 6 skyler.pearson@usdoj.gov 7 Attorneys for the United States 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 Case No. 2:23-cv-01886-JCM-NJK Eric Garza and Jose Garza, 11 Stipulation and Order to Extend the Plaintiffs, 12 United States’ Deadline to Answer or v. otherwise respond to Plaintiff’s 13 Complaint [ECF No. 1] Anthony Blinken, United States Secretary of 14 State; Rena Bitter, Assistant Secretary of State (First Request) for Consular Affairs: Julie Stufft, Deputy 15 Assistant Secretary of State for Visa Services; Eric Cohan, United States Consul General for 16 Ciudad Juarez, Mexico; and John Doe, Consular Officer for Ciudad Juarez, Mexico, 17 Defendants. 18 Plaintiffs, Eric Garza and Jose Garza, through counsel, and the United States of 19 America, on behalf of Federal Defendants, through counsel, hereby agree and stipulate to 20 extend the deadline to answer or otherwise respond to Plaintiff’s Complaint by 30 days, 21 until March 4, 2024.1 The parties enter into this stipulation based on the following: 22 1. Plaintiffs filed their Complaint on November 15, 2023 (ECF No. 1). 23 2. Plaintiff served the United States with a copy of the Summons and Petition 24 on December 4, 2023. 25 3. The current deadline for Federal Defendants to answer or otherwise respond 26 is February 2, 2024. 27 28 1 Thirty days from the current deadline, February 2, 2024, is March 3, 3024. March 3, 2024, falls on a Sunday. The 1 4, Since the filing and serving of the Complaint, the parties have engaged in 2 || discussions as to the Supreme Court’s grant of certiorari in Munoz v. U.S. Dep’t of State, 50 3 || F.4th 906 (9th Cir. 2022), cert. granted, No. 23-334, 2024 WL 133818 (Jan. 12, 2024) and its 4 || possible impact on the issues in this case. The requested 30-day extension will allow the 5 || parties additional time to work with their clients to allow additional discussion and come 6 ||up with a path moving forward. Should a responsive pleading be filed, Federal Defendants 7 || will move forward with responding to Plaintiffs’ Complaint on or before Mach 4, 2024. 8 || Accordingly, the parties believe good cause exists for the extension in the interest of 9 || judicial economy and the parties’ resources. 10 Therefore, the parties request that the Court extend the deadline for the United States 11 || to answer or otherwise respond to March 4, 2024. 12 Respectfully submitted this 2nd day of February 2024. 13 JASON M. FRIERSON 4 United States Attorney 15 |} /s/_ Anthony D. Guenther /s/ Skyler H. Pearson ANTHONY D. GUENTHER, ESQ. SKYLER H. PEARSON 16 || Nevada Bar No. 5651 Assistant United States Attorney 721 S. 6™ Street 17 |! Las Vegas, Nevada 89101 Attorneys for the United States 18 adg@adguentherlaw.com 19 Attorney for Plaintiff 20 21 IT IS SO ORDERED: 22 UNITED ES GISTRATE JUDGE 25 February 5, 2024 DATED: ebruary 9, 26 27 28