Opinion
2:22-cv-00435-APG-BNW
04-05-2023
GALLIAN WELKER & ASSOCIATES, L.C NATHAN E. LAWRENCE Attorney for Plaintiff JASON M. FRIERSON United States Attorney VIRGINIA T. TOMOVA Assistant United States Attorney Attorney for Defendants
GALLIAN WELKER & ASSOCIATES, L.C NATHAN E. LAWRENCE Attorney for Plaintiff
JASON M. FRIERSON United States Attorney VIRGINIA T. TOMOVA Assistant United States Attorney Attorney for Defendants
STIPULATION AND ORDER TO EXTEND TIME TO FILE A RESPONSE (FOURTH REQUEST)
Plaintiff and Defendants through undersigned counsel, hereby submit this stipulation to extend the date for Defendants to file and serve a responsive pleading to Plaintiff's First Amended Complaint (ECF No. 33, filed 1/31/23).
The current deadline for the United States to respond to the Plaintiff's Complaint is April 12, 2023.
The parties, through undersigned counsel, stipulate and request that the Court approve a four-weeks extension of time, from April 12, 2023, to May 15, 2023 for the United States of America to file a response to the First Amended Complaint. This is the fourth request for an extension of time. The additional time is needed because of a heavy case load given due to two AUSA vacancies in the Civil Division and multiple upcoming court-ordered deadlines. In addition, the parties are in the process of obtaining additional information regarding the allegations raised in the First Amended Complaint which is necessary to provide a responsive pleading.
Therefore, the parties request that the Court extend the deadline for the United States to answer or otherwise respond to May 15, 2023. Due to the stipulation, the parties also request that the Court extend the deadline for the Rule 26(f) conference from April 19, 2023, to June 5, 2023 and the deadline to submit the Joint Discovery Plan and Scheduling Order to June 19, 2023.
This stipulated request is filed in good faith and not for the purposes of undue delay.
Respectfully submitted this 5th day of April 2023.
IT IS SO ORDERED.