Opinion
2:23-cv-00849-CDS-VCF
08-04-2023
Jacqueline Garcia, Plaintiff, v. Eric S. Cohan, Stephanie Syptak-Ramnath, Antony Blinken, Defendants.
JASON M. FRIERSON UNITED STATES ATTORNEY PATRICK A. ROSE ASSISTANT UNITED STATES ATTORNEY
JASON M. FRIERSON UNITED STATES ATTORNEY
PATRICK A. ROSE ASSISTANT UNITED STATES ATTORNEY
UNOPPOSED MOTION FOR EXTENSION OF TIME
(FIRST REQUEST)
The Federal Defendants respectfully move for a 30-day extension of time, from August 4, 2023 to September 5, 2023, to file a response to Plaintiff's Complaint (ECF No. 1). This is the first request for an extension of time.
MEMORANDUM OF POINTS AND AUTHORITIES
Federal Rule of Civil Procedure 6(b)(1) and Local Rule IA 6-1 allow a party to request additional time to perform an act. In this case, the Federal Defendants request additional time to file a response to the Complaint for the reasons set forth below.
Defense counsel has recently returned to the office from being on leave for family reasons. Defense counsel is awaiting information and file materials from the client agency, the Department of State. This extension of time is requested to allow undersigned counsel adequate time to receive and review relevant information to prepare a response to the Complaint. Undersigned defense counsel has inquired with Plaintiff's counsel, who has no objection to this request for an extension of time. This motion is filed in good faith and not for the purposes of undue delay.
For the above reasons, the Federal Defendants respectfully request this extension of time, from August 4, 2023 to September 5, 2023, to file a response to Plaintiff's Complaint.
IT IS SO ORDERED.