Singh v. United States Department of Homeland Security

Filing 16

ORDER GRANTING Defendant's exparte application for initial 65-day extension of time to respond to complaint. Defendant's time to respond to the complaint is extended until 11/21/2012. Order signed by Magistrate Judge Sheila K. Oberto on 9/11/2012. (Timken, A)

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BENJAMIN B. WAGNER
United States Attorney
YOSHINORI H. T. HIMEL #66194
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
email: [e-mail]
Attorneys for Defendant
UNITED STATES DEPARTMENT OF HOMELAND SECURITY

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IN THE UNITED STATES DISTRICT COURT FOR THE

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EASTERN DISTRICT OF CALIFORNIA

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JASDEV SINGH,
Plaintiff,

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v.

1:12-cv-498-AWI-SKO-PS
DEFENDANT'S EX PARTE
APPLICATION FOR INITIAL 65-DAY
EXTENSION OF TIME TO RESPOND
TO COMPLAINT; ORDER

UNITED STATES DEPARTMENT
OF HOMELAND SECURITY AND
DOES 1-50,
Defendants.

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The U.S. Department of Homeland Security, defendant, applies under Local Rule

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144(c) for an initial 65-day extension of the time under Fed. R. Civ. P. 12(a)(2) for

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defendant's response to the complaint. The reason is that defense counsel needs more time to

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confer with the various concerned offices including the parts of Homeland Security's Office

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of Principal Legal Advisor that deal with Federal Tort Claims Act and the Privacy Act, two

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regional law offices in the Bureau of Prisons, this office's Criminal Division, and the DOJ

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Civil Division's Federal Programs Branch and Office of Immigration Litigation, to formulate

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defendant's position, to write a responsive motion, and to obtain internal review of the motion

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before filing. Scheduling constraints are explained in the accompanying counsel declaration.

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No previous extension of this time has been requested or granted. A suggested form of order

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is included in the event this application is granted.
DEFENDANT'S EX PARTE APPLICATION FOR INITIAL 65-DAY EXTENSION OF TIME TO RESPOND TO COMPLAINT; ORDER

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Dated: September 11, 2012

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ YHimel
YOSHINORI H. T. HIMEL
Assistant U.S. Attorney

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ORDER
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Upon defendant's ex parte application, good cause having been shown, defendant's
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time to respond to the complaint is extended until November 21, 2012.
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IT IS SO ORDERED.
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Dated:
ie14hj

September 11, 2012

/s/ Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE

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DEFENDANT'S EX PARTE APPLICATION FOR INITIAL 65-DAY EXTENSION OF TIME TO RESPOND TO COMPLAINT; ORDER

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