Sintigo v. Pompeo

1 THE PARIENTE LAW FIRM, P.C.

MICHAEL D. PARIENTE, ESQ.

2 || Nevada Bar No. 9469 3800 Howard Hughes Parkway, Suite 620 | Las Vegas, Nevada 89169 (702) 966-5310 Attorney for Plaintiff 6 UNITED STATES DISTRICT COURT STATE OF NEVADA Susan Sintigo, Case No.: 2:19-cv-465-APG-VCF 8 Plaintiff, | g ve. Mike P MOTION TO EXTEND TIME TO ecretary Mike Pompeo SUBMIT JOINT STATUS UPDATE | United States Department of State AND PROPOSED JOINT BRIEFING SCHEDULE 12 || Consul General Brendan O’Brien || 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 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 || proceed in this case.

25 DATED this 10* day of October, 2022.

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 12 13

Be 16 1g 1 MEMORANDUM 2 On February 4, 2022, this Honorable Court stayed Ms. Sintigo’s case for the purpose of waiting for the U.S. Ninth Circuit Court of Appeals to make its ruling in th 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 || astatus update within 5 days of the date of the Munoz decision and submit a propose || 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 |} AUSA assigned to this case appearing for the Defendant is out of the office per an |! 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 || respectfully requests a 14-day continuance to comply with the Court’s original order | 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 UNITED STATES DISTRICT JUDGE