Opinion
2:23-cv-00846-RFB-VCF
10-12-2023
EMILIO ESTEVEZ, Plaintiff, v. SAMANTHA POWER, Administrator of the United States Agency for International Development, LEILA EL GOHARY, Executive Secretary, Office of the Administrator United States Agency for International Development, JASON M. FRIERSON, United States Attorney for the District of Nevada, MERRICK GARLAND, United States Attorney General, United States Department of Justice, UNITED STATES DEPARTMENT OF STATE, FOREIGN SERVICE GRIEVANCE BOARD, Attn. Katherine Kaetzer-Hodson, Executive Secretary, Defendant(s). v.
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar No. 7709 VIRGINIA T. TOMOVA Assistant United States Attorney Attorneys for the United States
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar No. 7709 VIRGINIA T. TOMOVA Assistant United States Attorney Attorneys for the United States
STIPULATION AND ORDER (FIRST REQUEST)
Plaintiff Emilio Estevez and Defendants SAMANTHA POWER, Administrator of the United States Agency for International Development, LEILA EL GOHARY, Executive Secretary, Office of the Administrator United States Agency for International Development, JASON M. FRIERSON, United States Attorney for the District of Nevada, MERRICK GARLAND, United States Attorney General, United States Department of Justice, UNITED STATES DEPARTMENT OF STATE, and FOREIGN SERVICE GRIEVANCE BOARD, Attn. Katherine Kaetzer-Hodson, Executive Secretary (“Federal Defendants”), hereby stipulate and agree as follows:
Plaintiff filed his Complaint on May 30, 2023.
Plaintiff served the United States with a copy of the Summons and Complaint on August 16, 2023.
The current deadline for the United States to respond to the Plaintiff's Complaint is on October 16, 2023.
Plaintiff and the Federal Defendants, through undersigned counsel, stipulate and request that the Court approve a 30-day extension of time, from October 16, 2023, to November 16, 2023, for Federal Defendants to file a response to the Complaint, ECF No. 1. This is the first request for an extension of time.
The undersigned AUSA is preparing for a weeklong trial in another matter, starting December 4, 2023, preceded by an appellate brief in the Ninth Circuit due in three weeks from today, additional replies in other cases, depositions, and court hearings. This additional time will allow Defendants the necessary time to evaluate the case and to properly respond to Plaintiff's Complaint.
Therefore, the parties request that the Court extend the deadline for the United States to answer or otherwise respond to November 16, 2023.
This stipulated request is filed in good faith and not for the purposes of undue delay.
Respectfully submitted this 11th day of October 2023.
IT IS SO ORDERED: