Kids, when you need to ask a judge for an enlargement of time, this is how you do it:
This request is not meant to delay any matters before this Court. The Order was issued in the middle of the holiday season, and as Plaintiffs’ counsel clearly was not working as hard as the Court, were not addressed until after New Year’s. Moreover, if the extension of mercy is not sufficient cause, then Plaintiffs would suggest that waiting until after the pretrial stipulation may narrow the issues that the parties intend to try and the evidence which they intend to offer.
Counsel for the Plaintiffs, JC Atorcha, emailed and called counsel Robert Browning, in a good faith attempt to confer as to whether or not INA would oppose such relief. Undersigned counsel has not heard back from Mr. Browning, who may or may not still be celebrating the holidays.
Indeed, that may or may not be a photograph of Mr. Browning taken mid-revelry earlier this morning.
(I’m sure he’ll get back to JC later on today…..)