UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

JENNIFER VANDERSTOK et al.,

 Plaintiffs, Case No. 4:22-cv-00691-O

 v.

MERRICK GARLAND, in his official 

capacity as Attorney General of the United 

States et al., 

 Defendants.

DEFENDANTS’ MOTION FOR EXTENSION OF TIME

Defendants respectfully move this Court for a one-week extension for the parties to file 

supplemental briefs, in the event that no motion to supplement the Administrative Record is filed. In 

support of this motion, Defendants state as follows:

1. The Court has directed that any motions seeking supplementation of the 

Administrative Record are due on or before November 14, 2022 (ECF No. 105). 

2. The Court has ordered the parties to file supplemental briefs on the Court’s Rule 

65(a)(2) consolidation of Plaintiffs’ statutory interpretation claims (ECF No. 107). The Court has 

directed that such briefs are due either 14 days after the Court resolves any pending motion to

supplement the Administrative Record and such supplemental records, where required, are produced; 

or no later than November 28, 2022, if no such motion is filed (ECF No. 110). 

3. The drafting of the parties’ supplemental briefs will require coordination and 

consultation with their clients, but because the week immediately preceding November 28 is 

Thanksgiving Week, it is likely that there will be widespread absences from office on the part of 

counsel for all parties, which will frustrate their efforts to consult with their clients.

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4. Defendants therefore respectfully request a one-week extension—from November 28 

to December 5, 2022—of the deadline for the parties to file their supplemental briefs, in the event 

that no motion to supplement the Administrative Record is filed.

5. Counsel for Plaintiffs Jennifer VanDerStok; Michael G. Andren; Tactical Machining, 

LLC; and Firearms Policy Coalition, Inc. (the original plaintiffs) take no position on this motion. 

Counsel for Plaintiff BlackHawk Manufacturing Group Inc. (intervenor-plaintiff) is not opposed to 

this motion.

Accordingly, Defendants respectfully request that their motion for extension of time be 

granted. 

DATED: August 26, 2022 Respectfully submitted,

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General

ALEXANDER K. HAAS

Director, Federal Programs Branch

LESLEY FARBY

Assistant Director, Federal Programs Branch

/s/ Daniel Riess

DANIEL RIESS

MARTIN M. TOMLINSON

TAISA M. GOODNATURE

Trial Attorneys

Civil Division, Federal Programs Branch

U.S. Department of Justice

1100 L Street, NW

Washington, DC 20005

Phone: (202) 353-3098

Email: Daniel.Riess@usdoj.gov

Attorneys for Defendants

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CERTIFICATE OF CONFERENCE

I certify that I have conferred with Plaintiffs’ counsel to obtain their position on this motion. 

Counsel for the original plaintiffs have stated that the original plaintiffs take no position on this 

motion. Counsel for intervenor-plaintiff have stated that intervenor-plaintiff is not opposed to the 

relief sought in this motion.

/s/ Daniel Riess

CERTIFICATE OF SERVICE

On October 31, 2022, I electronically submitted the foregoing document with the clerk of 

court for the U.S. District Court, Northern District of Texas, using the electronic case filing system 

of the court. I hereby certify that I have served all parties electronically or by another manner 

authorized by Federal Rule of Civil Procedure 5(b)(2).

/s/ Daniel Riess

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