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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

AMARILLO DIVISION 

) 

STATE OF TEXAS, ) 

 ) 

Plaintiff, ) 

 ) 

v. ) Civil Action No. 2:22-cv-00094-Z

) 

ALEJANDRO MAYORKAS, ) 

in his official capacity as ) 

Secretary of Homeland Security, et al., ) 

 ) 

Defendants. ) 

 ) 

JOINT MOTION TO EXTEND SCHEDULE 

 

The parties jointly request that the Court extend the deadlines to complete jurisdictional 

discovery and for the Parties to submit updated proposals for additional briefing and proceedings 

by 14 days, to allow the Parties time to fully respond to the jurisdictional discovery that has already 

been served. 

On May 31, 2022, the Court set the following deadlines for this case: 

 Defendants to produce the administrative record on or before June 3, 2022; 

 Parties to send all jurisdictional discovery requests on or before June 15, 2022; 

 Parties to complete all jurisdictional discovery on or before July 1, 2022; 

 Parties to submit updated proposals for additional briefing and proceedings on or 

before July 6, 2022. 

May 31 Order, ECF No. 60. 

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Defendants produced the administrative record on June 3, 2022. And the Parties served 

jurisdictional discovery by the June 15, 2022 deadline. On June 7, 2022, Defendants served Texas 

with a deposition notice under Rule 30(b)(6). On June 10, 2022, Defendants served Texas with 

written discovery requests. On June 15, 2022, Texas served Defendants with written discovery 

requests. 

 The Parties now jointly request a short 14-day extension to allow the Parties to complete 

the discovery that has already been served. The Parties are working on collecting documents and 

preparing responses, but would benefit from additional time to ensure that they can provide 

thorough and complete responses. Texas also has not yet been able to identify deponent(s) and 

proposed dates in response to the June 7 deposition notice, and the Parties will need additional 

time to schedule and complete that deposition or depositions after Texas identifies the proper 

deponents and can provide their availability.1

 

If the Court grants this short extension, the remaining deadlines from the Court’s May 31 

order will be: 

 Parties to complete all jurisdictional discovery on or before July 15, 2022; 

 Parties to submit updated proposals for additional briefing and proceedings on or 

before July 20, 2022. 

The Parties jointly request that the Court grant this short extension. 

 

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 The Parties are hopeful that they can identify agreed-upon dates to complete the depositions 

before July 15, 2022. However, given the press of other business, including preexisting deadlines 

and scheduled depositions arising from expedited discovery taking place in other matters during 

the same time period, if the deponents have limited availability it may be difficult to do so. The 

Parties will confer once Texas identifies deponents and their availability to try to work out a 

schedule for completing this discovery prior to July 15, and will advise the Court if they are unable 

to do so. 

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Dated: June 24, 2022 Respectfully submitted, 

 

 BRIAN M. BOYNTON 

 Principal Deputy Assistant Attorney General 

WILLIAM C. PEACHEY 

Director 

Office of Immigration Litigation 

District Court Section 

EREZ REUVENI 

Assistant Director 

 /s/ Brian C. Ward 

 BRIAN C. WARD 

 Senior Litigation Counsel 

 U.S. Department of Justice 

 Civil Division 

Office of Immigration Litigation 

District Court Section 

P.O. Box 868, Ben Franklin Station 

Washington, DC 20044 

Tel.: (202) 616-9121 

brian.c.ward@usdoj.gov 

 

Counsel for Defendants 

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KEN PAXTON AARON F. REITZ 

Attorney General of Texas Lead Counsel

Deputy Attorney General for Legal Strategy 

BRENT WEBSTER Texas Bar No. 24105704 

First Assistant Attorney General aaron.reitz@oag.texas.gov 

 

OFFICE OF THE ATTORNEY GENERAL LEIF A. OLSON 

P.O. Box 12548 Special Counsel 

Austin, Texas 78711-2548 Texas Bar No. 24032801 

(512) 936-1700 leif.olson@oag.texas.gov 

GENE P. HAMILTON 

America First Legal Foundation 

300 Independence Avenue SE 

Washington, DC 20003 

(202) 964-3721 

gene.hamilton@aflegal.org 

Counsel for Plaintiff

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CERTIFICATE OF CONFERENCE 

I hereby certify that on June 24, 2022, I conferred with counsel for Plaintiff about the 

relief requested in this motion. Plaintiff joins this request. 

/s/ Brian C. Ward 

BRIAN C. WARD 

U.S. Department of Justice 

CERTIFICATE OF SERVICE 

I hereby certify that on June 24, 2022, I electronically filed this motion with the Clerk of 

the Court for the United States District Court for the Northern District of Texas by using the 

CM/ECF system. Counsel in the case are registered CM/ECF users and service will be 

accomplished by the CM/ECF system. 

/s/ Brian C. Ward 

BRIAN C. WARD 

U.S. Department of Justice 

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