MGA Entertainment Inc v. Mattel Inc et al

Filing 54

[PUBLIC REDACTED] OPPOSITION to MGA and Bryants Motion to Compel, etc. filed by plaintiff Mattel Inc. (de, )

Case 2:05-cv-02727-SGL-RNB Document

Filed 04/25/05 Page 1 of 2

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THOMAS P. O'BRIEN United States Attorney LEON W. WEIDMAN Assistant United States Attorney Chief, Civil Division THOMAS K. BUCK Assistant United States Attorney California Bar No. 70307 Room 7516 Federal Building 300 North Los Angeles Street Los Angeles, California 90012 Telephone: [phone] Fax No.: [phone] [e-mail] Attorneys for Defendants UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA MAMDOUH HABIB, Plaintiff, v. MICHAEL MUKASEY, etc., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV 08-01135 GHK(MANx) STIPULATION FOR ORDER OF REMAND TO CITIZENSHIP AND IMMIGRATION SERVICES

Hon. George H. King

WHEREAS: A. § 1447(b); B. Citizenship and Immigration Service ("CIS") has advised its undersigned counsel that it is prepared to adjudicate the underlying naturalization application within 30 days of entry of an order of remand; and C. Remanding this matter to CIS for adjudication will promote judicial economy and will not bar plaintiff from seeking administrative review and filing a Plaintiff has filed a naturalization complaint pursuant to 28 U.S.C.

Case 2:05-cv-02727-SGL-RNB Document

Filed 04/25/05 Page 2 of 2

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subsequent District Court action if the naturalization application is denied. See 8 U.S.C. §§ 1421(c) & 1447(a). Plaintiff and defendants, through respective counsel, HEREBY STIPULATE THAT: 1. remand. 2. If within 30 days of the entry of the order of remand the underlying naturalization application has not been adjudicated, then the parties must file a Joint Report on or before the 45th day following entry of the order of remand. 3. Each party will bear its own costs, fees and expenses. LAW OFFICES OF HALEH MANSOURI /s/ Haleh Mansouri signed by Thomas K. Buck* ________________________________ Haleh Mansouri Attorneys for Plaintiff Mambouh Habib *pursuant to authority emailed on 3/27/08 DATED: 3/28/08 THOMAS P. O'BRIEN United States Attorney LEON W. WEIDMAN Assistant United States Attorney Chief, Civil Division /s/ Thomas K. Buck THOMAS K. BUCK Assistant United States Attorney Attorneys for Defendants
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This matter should be remanded to CIS with instructions to adjudicate

the underlying naturalization application within 30 days of entry of the order of

DATED: 3/28/08