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’ UNOPPOSED MOTION FOR EXTENSION OF TIME

Defendants respectfully move this Court for a ten-day extension for Defendants to file their 

reply brief in support of their cross-motion for summary judgment (ECF No. 180). In support of this 

motion, Defendants state as follows:

1. Original plaintiffs’ and intervenor-plaintiffs’ opposition briefs to Defendants’ crossmotion were filed on March 6, 2023. See ECF Nos. 191-93. 

2. Under the Court’s Scheduling Order (ECF No. 105), Defendants’ Response & CrossMotion for Summary Judgment is presently due on March 27, 2023.

3. Defendants require additional time to prepare their responses and cross-motion for 

summary judgment because the original schedule was negotiated under the expectation of responding 

to one summary judgment opposition rather than two, because Defendants have been expending 

considerable litigation resources briefing a motion for a temporary restraining order and preliminary 

injunction in another case pending before this Court, and because of the press of business and other 

litigation.

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

LLC; and Firearms Policy Coalition, Inc. (the original plaintiffs), as well as counsel for Plaintiffs 

BlackHawk Manufacturing Group Inc.; Defense Distributed; and Second Amendment Foundation, 

Inc. (intervenor-plaintiffs) are not opposed to this motion.

Accordingly, Defendants respectfully request that their unopposed motion for extension of 

time be granted.

DATED: March 20, 2023 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

CERTIFICATE OF CONFERENCE

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

Counsel for both the original plaintiffs and intervenor-plaintiffs have stated that they are not opposed 

to the relief sought in this motion.

/s/ Daniel Riess

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CERTIFICATE OF SERVICE

On March 20, 2023, 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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