Khalsa v. Melville et al

Filing 7


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Case 3:08-cv-05659-WHA Document 6 Filed 02/20/2009 Page 1 of 2 1 J OSEPH P. RUSSONIELLO, CSBN 44332 United States Attorney 2 J OANN M. SWANSON, CSBN 88143 Assistant United States Attorney 3 Chief, Civil Division ILA C. DEISS, NY SBN 3052909 4 Assistant United States Attorney 5 6 7 8 Attorneys for Defendants 9 10 11 12 KARNAIL SINGH KHALSA, 13 14 15 16 17 18 19 20 21 22 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) No. C 08-5659 WHA Plaintiff, ) ) ROSEMARY MELVILLE, Director, USCIS ) STIPULATION TO EXTEND DATES; San Francisco District Office; ROBIN L. Barrett, ) AND [PROPOSED] ORDER Field Office Director; USCIS San Francisco ) District Office; GERARD HEINAUER, Director, ) USCIS Nebraska Service Center; MICHAEL ) AYTES, Acting Deputy Director, USCIS; U.S. ) Citizenship and Immigration Services; ) MICHAEL CHERTOFF, Secretary, USDHS; ) U.S. Department of Homeland; ROBERT S. ) MUELLER, Director, Federal Bureau of ) Investigations; MICHAEL B. MUKASEY, ) U.S. Attorney General, ) ) D ef en d a n t s . ) ) The Plaintiff, by and through his attorney of record, and Defendants by and through their 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102 Telephone: (415) 436-7124 FAX: (415) 436-7169 23 attorneys of record, hereby stipulate, subject to the approval of the Court, to a 60-day extension of 24 Defendants' answer. Plaintiff is scheduled for an interview on his adjustment of status application 25 on February 27, 2009, and the parties agree that there is a reasonable likelihood that this case can 26 be administratively resolved in the next 60 days, and that the case will be moot. 27 Accordingly, the parties respectfully ask this Court to extend the date of Defendants' answer 28 by 60 days. If the case becomes moot, the parties will file a stipulation to dismiss. If the case is Stipulation to Extend C08-5659 WHA 1 Case 3:08-cv-05659-WHA Document 6 Filed 02/20/2009 Page 2 of 2 1 not administratively resolved, the Defendants will file their answer to Plaintiff's complaint. 2 Date: February 20, 2009 3 4 5 6 7 8 9 Date: February 20, 2009 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 I, Ila Deiss, hereby attest that I have on file all holograph signatures for any signatures 28 indicated by a "conformed" signature (/S/) within this efiled document. Stipulation to Extend C08-5659 WHA 1 Respectfully submitted, J OSEPH P. RUSSONIELLO United States Attorney /s/ ILA C. DEISS1 Assistant United States Attorney Attorneys for Defendants /s/ ROBERT B. JOBE Attorney for Plaintiff O RD ER S DISTRICT TE C TA RT U O UNIT ED S Pursuant to stipulation, IT IS SO ORDERED. Date: February 25, 2009 l ugW ________J_d_e__il_______________ WILLIE M ALSUP A RN United States District C Judge OF D IS T IC T R 2 A LI FO iam Als up R NIA O ORD IT IS S ERED NO RT H

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