Dunne et al v. U.S. Department of Homeland Security et al

Filing 7

STIPULATION AND ORDER EXTENDING TIME TO ANSWER re 6 Stipulation, filed by U.S. Department of Homeland Security, Timothy S. Aitken, U.S. Department of Justice, Eric H. Holder, Jr., Immigration and Customs Enforcement, Janet Napolitano. Signed by Judge Edward M. Chen on 3/22/11. (bpf, COURT STAFF) (Filed on 3/22/2011)

Dunne et al v. U.S. Department of Homeland Security et al

Doc. 7

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TONY WEST Assistant Attorney General Civil Division KATHERINE E.M. GOETTEL (Iowa #23821) Trial Attorney Office of Immigration Litigation Civil Division, Justice Department P.O. Box 878, Ben Franklin Station Washington, D.C. 20044 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorneys for Defendants

8 9 10 11 12 13 14 15 16 17 18 Plaintiffs, by and through his attorneys of record, and Defendants, by and through their 19 attorneys of record, stipulate to the following: 20 1. Plaintiffs filed a complaint in this action on December 13, 2010. Plaintiffs perfected 21 service on January 21, 2011. Without an extension, Defendants' deadline to answer or respond is 22 March 22, 2011. 23 2. The Defendants are in the process of gathering information and documents, and 24 determining their position on this case, and require additional time to complete these tasks before 25 filing an answer or responsive pleadings. 26 3. Therefore, the parties hereby respectfully request this Court to order a thirty-day 27 28
STIPULATION FOR EXTENSION OF TIME Case No. C 10-5636

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) Plaintiffs, ) ) vs. ) ) DEPARTMENT OF HOMELAND ) SECURITY; ATTORNEY GENERAL ) ERIC H. HOLDER, JR.; IMMIGRATION ) AND CUSTOMS ENFORCEMENT; ) TIMOTHY S. AITKEN, ) ) Defendants. ) ____________________________________) MARK ANTHONY DUNNE; AUDREY GRACE FITZSIMMONS, Case No. 3:10-cv-05636-EMC STIPULATION TO EXTEND DATES AND [PROPOSED] ORDER

Dockets.Justia.com

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extension of time within which the Defendants must serve its response in the above-entitled action. Defendants will file their response on or before April 21, 2011.

Respectfully submitted, Dated: March 22, 2011 s/ Katherine E.M. Goettel KATHERINE E.M. GOETTEL Trial Attorney United States Department of Justice Civil Division Office of Immigration Litigation District Court Section P.O. Box 868, Ben Franklin Station Washington, D.C. 20044 [phone] [phone] (fax) E-mail: [e-mail] s/ James M. Byrne Law Offices of James M. Byrne 1374 Pacific Avenue San Francisco, CA 94109 415 777-4444 Fax: [phone] Email: [e-mail]

6 7 8 9 10 11 12 Dated: March 22, 2011 13 14 15 16 17 18 19 20 21 22 23 24 25 Date: March 22, 2011

ORDER

Pursuant to stipulation, IT IS SO ORDERED.

UNIT ED

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S DISTRICT TE C TA

United States Magistrate Judge
J ward M udge Ed . Chen

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STIPULATION FOR EXTENSION OF TIME Case No. C 10-5636

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 22, 2011

CERTIFICATE OF SERVICE I hereby certify that on March 22, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify this document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronic Notices of Electronic Filing.

/s/ Katherine E.M. Goettel KATHERINE E.M. GOETTEL

STIPULATION FOR EXTENSION OF TIME Case No. C 10-5636

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