Ibrahim v. Department of Homeland et al

Filing 151

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE TO MARCH 12, 2009, AT 3:00 P.M. Signed by Judge William Alsup on 2/9/2009. (whasec, COURT STAFF) (Filed on 2/9/2009)

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MICHAEL F. HERTZ Acting Assistant Attorney General, Civil Division SANDRA M. SCHRAIBMAN Assistant Branch Director PAUL G. FREEBORNE Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6108 Washington, D.C. 20001 Phone: [phone]--Fax: [phone] UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RAHINAH IBRAHIM, Plaintiff, v. ) ) ) ) ) ) ) ) ) ) ) No. 3:06-cv-00545 (WHA) STIPULATION REQUESTING ORDER TO CHANGE DATE OF CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER [CIVIL L.R. 6-1(a), 7-12] Hon. William H. Alsup

DEPARTMENT OF HOMELAND 12 SECURITY, et al., 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Pursuant to Local Rule 6-1(a) and 7-12, the parties hereby submit this stipulated request for an order to change the date of the case management conference scheduled for February 12, 2008. RECITALS 1. this Court. 2. By Notice, dated January 28, 2009, Dkt. 149, a case management conference was On December 24, 2009, the Ninth Circuit issued its mandate returning this case to

scheduled for February 12, 2009. 3. The parties jointly request that they be afforded additional time to file a joint case

management statement, and that the case management conference currently scheduled for February 12, 2009 be continued for a month. The parties request this additional time to consider jointly how best to advance these proceedings. If granted, the parties would submit a joint case management conference statement seven days prior to the date of the conference.
No. 3:06-cv-00545 (WHA) ­ Stipulation Requesting Order to Change Date of Case Management Conference

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4.

This is the parties' first request to change the date of the case management

conference. Granting this request would not alter any other dates established in these proceedings. 5. Government counsel will be traveling to Riverside, California for oral argument in

the Central District of California on March 9, 2009, and would request that the conference be rescheduled for the next day, March 10, 2009, if that date is available on the Court's calendar. Government counsel has conferred with counsel for the other parties, and counsel are all available on that date. STIPULATION Pursuant to Local Rule 6.1(a) and 7-12, the parties hereby jointly request an order

11 changing the date of the case management conference, and that the conference be rescheduled for 12 March 10, 2009, if that date is available on the Court's calendar. 13 Dated: February 2, 2009 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
No. 3:06-cv-00545 (WHA) ­ Stipulation Requesting Order to Change Date of Case Management Conference

Respectfully Submitted, MICHAEL F. HERTZ Acting Assistant Attorney General, Civil Division SANDRA M. SCHRAIBMAN Assistant Branch Director /s/ Paul G. Freeborne PAUL G. FREEBORNE United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6108 Washington, D.C. 20001 Phone: [phone]--Fax: [phone] Email: [e-mail] Attorneys for the Federal Defendants

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DECLARATION PURSUANT TO GENERAL ORDER 45, § X.B. I, PAUL G. FREEBORNE, hereby declare pursuant to General Order 45, § X.B., that I have obtained the concurrence in the filing of this document from each of the other signatories listed below. I declare under penalty of perjury that the foregoing declaration is true and correct. Executed on February 2, 2009, in the City of Washington, District of Columbia. /s/ Paul G. Freeborne PAUL G. FREEBORNE United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, NW, Rm. 6108 Washington, D.C. 20001 Phone: [phone]--Fax: [phone] Email: [e-mail] Attorneys for the Federal Defendants /s/ Marwa Elzankaly_____________ MARWA ELZANKALY McMANNIS FAULKNER & MORGAN 50 West San Fernando Street Suite 1000, Tenth Floor San Jose, CA 95113 Phone: [phone]­Fax: [phone] Email: [e-mail] Attorneys for Plaintiff /s/ Ronald P. Flynn RONALD P. FLYNN Deputy City Attorney SAN FRANCISCO CITY ATTORNEY'S OFFICE 1390 Market Street, Sixth Floor San Francisco, CA 94102 Phone: [phone]­Fax: [phone] Email: [e-mail] Attorneys for Defendants City and County of San Francisco

No. 3:06-cv-00545 (WHA) ­ Stipulation Requesting Order to Change Date of Case Management Conference

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/s/ Sharon Douglass Mayo ARNOLD & PORTER LLP 275 Battery Street, Suite 2700 San Francisco, CA 94111 Phone: [phone]­Fax: [phone] Email: [e-mail] Attorneys for John Bondanella and U.S. Investigations Services, Inc.

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PROPOSED ORDER It is hereby ORDERED that the case management conference scheduled for February 12, March 12, 2009, at 3:00 p.m. 2009 is continued until March 10, 2009 at ______________ _.m. The parties shall file a joint case management conference statement 7 calendar days in advance of the case management conference.

IT IS SO ORDERED, January 9 Dated: _____________, 2009
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