1 SAIcGtiAngL U CnHitAedT STtAatHes Attorney 2 District of Nevada Nevada Bar No. 8264 3 VIRGINIA T. TOMOVA Assistant United States Attorney 4 Nevada Bar No. 12504 501 Las Vegas Blvd. So., Suite 1100 5 Las Vegas, Nevada 89101 Phone: (702) 388-6336 6 Fax: (702) 388-6336 [email protected] 7 Attorneys for the Federal Respondents 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 AGUSTIN MARTINEZ-CELIS, Case No. 2:25-cv-01650-MMD-NJK 11 Petitioner, Order Granting Stipulation for Extension of time to Respond to 12 v. Petition for Writ of Habeas Corpus 13 KRISTI NOEM, Secretary of the U.S. (First Request) Department of Homeland Security; PAM 14 BONDI, Attorney General of the United States; TODD LYONS, Director of United 15 States Immigration and Customs Enforcement; BRYAN WILCOX, Field 16 Office Director for Detention and Removal, U.S. Immigration and Customs 17 Enforcement; JOHN MATTOS, Warden, Nevada Southern Detention Center; U.S. 18 Department of Homeland Security; U.S. Immigration and Customs Enforcement; 19 Respondents. 20 21 Petitioner Agustin Martinez-Celis, through undersigned counsel, and the United 22 States of America, on behalf of Federal Respondents, through undersigned counsel, hereby 23 stipulate to an extension of time to respond to Petitioner Agustin Martinez-Celis’ 24 (“Petitioner”) Petition for Writ of Habeas Corpus (“Petition”) (ECF No. 1). Federal 25 Respondents’ response to Petition for Writ of Habeas Corpus is currently due on 26 September 25, 2025. For the reasons discussed below, Federal Respondents request that 27 this time be extended up to and including September 30, 2025. 28 1 Under Federal Rule of Civil Procedure 6(b), a court may, “for good cause,” extend 2 a deadline if a request is made “before the original time or its extension requires.” Fed. R. 3 Civ. P. 6(b)(1)(A); see also Local Rule IA 6-1(a). The Ninth Circuit has equated good cause 4 with the exercise of due diligence. See Johnson v. Mammoth Recreations, Inc.,

, 5 609 (9th Cir. 1992). Additionally, Fed. R. Civ. P. 6(b)(1) should “be liberally construed to 6 effectuate the general purpose of seeing that cases are tried on the merits,” and “requests 7 for extensions of time made before the applicable deadline has passed should normally be 8 granted in the absence of bad faith or prejudice to the adverse party.” Ahanchian v. Xenon 9 Pictures, Inc.,

, 1258–59 (9th Cir. 2010) (internal citations omitted). 10 Federal Respondents have good cause to request this extension of time. Federal 11 Respondents’ counsel needs additional time to obtain all responsive information regarding 12 the Petition from its clients to meaningfully respond to the Petition. The Civil Division is 13 also currently dealing with attorney staffing shortages and has received nine petitions for 14 writ of habeas corpus – all with either expedited briefing for temporary restraining orders or 15 briefing within 20 days. 16 In view of the circumstances explained above, the United States has good cause to 17 request a 5-day extension to file a response to Petitioner’s Petition. 18 19 20 21 22 23 24 25 26 27 28 1 This is the first request to extend the Respondents’ responsive pleading deadline. 2 || This is request is made in good faith and not for the purpose of undue delay. 3 Respectfully submitted this 25th day of September 2025. 4 S|| /s/_Ashlee Hesman SIGAL CHATTAH 6 ASHLEE HESMAN Acting United States Attorney 3100 West Ray Road, Ste. 300 Is! Viveinia TT. 7|| Chandler, Arizona 85226 fst Fe Tomorg——_— T TOMOV A Asorney for Respondent Assistant United States Attorney John Mattos, Warden, Nevada Southern Attorneys for the Federal Respondents 9|| Detention Center 10 11|| /s/ Jeremy Mondejar JEREMY MONDEJAR, ESQ. 12}| 2885 E. Charleston Blvd., Suite 10 3 Las Vegas, Nevada 89104 14 Attorney for Petitioner 15 16 17 18 19 IT IS SO ORDERED: 20 21 29 TED STATES DISTRICT JUDGE 3 DATED: September 26, 2025 24 25 26 27 28