Chris Geidner
‪@chrisgeidner.bsky.social‬

A reminder that, in the midst of everything else, the Trump administration is an incredible combination of entitlement and sloppiness.

DOJ: "We were too busy invading Venezuela to address your court order, Chief Judge Boasberg."

Boasberg: "You didn't even follow the rules in filing this request."

Case 1:25-cv-00766-JEB
Document 223
Filed 01/04/26
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LIYANARA SANCHEZ, as next friend on behalf of FRENGEL REYES MOTA, et al.,
Petitioners-Plaintiffs,
J.G.G., et al.,
Plaintiffs,
Case No: 1:25-cv-00766-JEB
V.
DONALD J. TRUMP, in his official capacity as President of the United States, et al.,
Respondents-Defendants.
DEFENDANTS' MOTION FOR AN EXTENSION
Given substantial changes on the ground in Venezuela and the fluid nature of the unfolding
situation, Defendants respectfully move for an extension to respond to this Court's Order (ECF
214) directing them to propose a remedy by Monday, January 5. Over the weekend, the United
States apprehended Nicolas Maduro. As a result, the situation on the ground in Venezuela has
changed dramatically. Defendants thus need additional time to determine the feasibility of various
proposals. Defendants therefore request a 7-day extension to evaluate and determine what
remedies are possible.
ALT

Dated: January 4, 2025
Respectfully submitted,
Brett A. Shumate
Assistant Attorney General
Civil Division
Drew C. Ensign
Deputy Assistant Attorney General
Case 1:25-cv-00766-JEB
• Document 223
Filed 01/04/26 Page 2 of 2
Office of Immigration Litigation
/s/ Tiberius Davis
Tiberius Davis
Counsel to the Assistant Attorney General
Civil Division
U.S. Department of Justice
Anthony Nicastro
Acting Director
Office of Immigration Litigation
Counsel for Respondents-Defendants
ALT

MINUTE ORDER: As the Government's 223 Motion fails to comply with LCvR 7(m), the Court ORDERS that it shall file a Rule 7(m) Notice by 5:00 p.m. today. So ORDERED by Chief Judge James E. Boasberg on January 5, 2026. (Icjeb4)
Order
ALT

(m)
DUTY TO CONFER ON NONDISPOSITIVE MOTIONS.
Before filing any nondispositive motion in a civil action, counsel shall discuss the anticipated motion with opposing counsel in a good-faith effort to determine whether there is any opposition to the relief sought and, if there is, to narrow the areas of disagreement. The duty to confer also applies to non-incarcerated parties appearing pro se. A party shall include in its motion a statement that the required discussion occurred, and a statement as to whether the motion is opposed.
ALT
3:02 PM · Jan 5, 2026

Chris Geidner
‪@chrisgeidner.bsky.social‬

UPDATE: DOJ conferred with the plaintiffs, who DID NOT OPPOSE the 7-day extension so long as DOJ agreed not to ask for further extensions — and DOJ then said no!

tl;dr: DOJ asked Boasberg for a 7-day extension on Saturday, then told the plaintiffs on Monday they might ask for more.

DEFENDANTS’ LOCAL CIVIL RULE 7(m) NOTICE
Pursuant to this Court’s minute order of January 5, 2026, Defendants notify this Court that
they have met and conferred with Plaintiffs on Defendants’ January 4 Motion for an Extension.
Plaintiffs do not oppose an extension until Monday on the condition that Defendants do not seek
additional extensions. Given the fluid situation, Defendants cannot currently agree to that
limitation.
Dated: January 5, 2026 Respectfully submitted,
Brett A. Shumate
Assistant Attorney General
Civil Division
Drew C. Ensign
Deputy Assistant Attorney General
Office of Immigration Litigation
/s/ Tiberius Davis
Tiberius Davis
Counsel to the Assistant Attorney General
Case 1:25-cv-00766-JEB Document 224 Filed 01/05/26 Page 1 of 2
2
Civil Division
U.S. Department of Justice
Anthony Nicastro
Acting Director
Office of Immigration Litigation
Counsel for Respondents–Defendants
ALT
5:28 PM · Jan 5, 2026