Sintigo v. Pompeo

Opinion

MICHAEL D. PARIENTE, ESQ. 2 Nevada Bar No. 9469 3800 Howard Hughes Parkway, Suite 620 3 Las Vegas, Nevada 89169 4 (702) 966-5310 Attorney for Plaintiff 5 STATE OF NEVADA 7 Susan Sintigo, Case No.: 2:19-cv-465-APG-VCF 8 Plaintiff, 9 10 g ve. Mike P MOTION TO EXTEND TIME TO ecretary Mike Pompeo SUBMIT JOINT STATUS UPDATE 11 United States Department of State AND PROPOSED JOINT BRIEFING SCHEDULE 8 12 || Consul General Brendan O’Brien 13 Attorney General William Barr (First Request) 14. } United States Department of Justice

Does I-IX 16 Defendants.

18 This is a request for first extension of time made pursuant to LR IA 6-1. 19 COMES NOW Plaintiff Susan Sintigo and files this first request for extension o 20 time to update this Honorable Court on the status of the U.S. Ninth Circuit Court of

99 Appeals’ decision in Munoz v. United States Dep't of State, No. 21-55365, 2022 WL 23 5089771 (9th Cir. Oct. 5, 2022) and to submit a proposed joint briefing schedule to 24 proceed in this case. 25 DATED this 10* day of October, 2022. 26 37 Respectfully submitted, 28 /s/ Michael D. Pariente

THE PARIENTE LAW FIRM, P.C. MICHAEL D. PARIENTE, ESQ. 2 Nevada Bar No. 9469 3800 Howard Hughes Parkway, Suite 62 3 Las Vegas, Nevada 89169 A Phone: (702) 966-5310 Attorney for Susan Sintigo 5 6 7 8 9 10 11 2 12 2 13

Be 16

2 1g 19 20 21 22 23 24 25 26 27 28

2 On February 4, 2022, this Honorable Court stayed Ms. Sintigo’s case for the 3 purpose of waiting for the U.S. Ninth Circuit Court of Appeals to make its ruling in th 4 case of Munoz v. United States Dep't of State, No. 21-55365, 2022 WL 5089771 (9th Ci Oct. 5, 2022). [ECF Docket No. 60]. Both Plaintiff and the Defendant were to provide 7 astatus update within 5 days of the date of the Munoz decision and submit a propose 8 briefing schedule to proceed in this case. ? On October 5, 2022, the U.S. Ninth Circuit Court of Appeals issued its decision in Munoz, supra. However, counsel for Plaintiff and Defendant have not had sufficien time to confer to comply with the Court’s request. Today is a federal holiday and the 13 } AUSA assigned to this case appearing for the Defendant is out of the office per an 14 ! electronic email return sent from his office indicating he is out of the office from IS October 5, 2022 to October 10, 2022. Therefore, Plaintiff and Defendant need additional time to comply with the Court’s order granting the stipulation. Plaintiff 18 respectfully requests a 14-day continuance to comply with the Court’s original order 19 and for the parties to explore negotiations in light of the Munoz decision. 20 DATED this 10 day of October, 2022. Respectfully submitted, 13 /s/ Michael D. Pariente 24 Michael D. Pariente, Esq. 95 Attorney for Plaintiff Susan Sintigo 36 IT IS SO ORDERED: 37 Dated: October 11, 2022

ANDREW P. GORDON