Sohaib v. Christian et al

Filing 8

ORDER GRANTING re 6 Stipulation For Extension of Time to Answer or Otherwise Respond to the Complaint filed by Gregory W. Christian, Eric Holder, Janet Napolitano. Signed by Judge Joseph C. Spero on 1/10/13. (klhS, COURT STAFF) (Filed on 1/10/2013)

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1 2 3 4 MELISSA LEIBMAN, NYSBN 4442877 Trial Attorney United States Department of Justice Office of Immigration Litigation, DCS 450 5th Street, NW Washington, DC 20001 Tel: (202) 305-7016; Fax: (202) 305-7000 Email: Melissa.Leibman@usdoj.gov 5 Attorneys for Defendants 6 7 8 9 Ashwani K. Bhakhri, Esq., SBN# 163521 Law Offices of Ashwani K. Bhakhri 1299 Bayshore Highway, Suite 208 Burlingame, California 94010 Telephone: (650) 685-6334 Facsimile: (650) 685-6351 Email: bhakhrilaw2004@yahoo.com 10 Attorney for Plaintiff 11 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 12 13 14 15 Mohammed Hamza Sohaib, Plaintiff, 16 17 18 19 20 v. Gregory Christian, Acting Director USCIS Nebraska Service Center; Janet Napolitano, Secretary of the Department of Homeland Security; and Eric H. Holder, Jr., United States Attorney General, No. 12-03867 JCS STIPULATION for Extension of Time to Answer or Otherwise Respond to the Complaint and [PROPOSED] ORDER Immigration Case, Mandamus Before: Magistrate Judge Joseph C. Spero Defendants. 21 22 23 Stipulation RE Extension of Time to Answer Case No. 12-03867 JCS 1 1 The parties hereby respectfully request that this Court approve the parties’ stipulation to 2 extend Defendants’ time to answer or otherwise respond to Plaintiffs’ Complaint. The parties 3 agree to the following terms: 4 1. 5 Answer or Response is currently due on January 12, 2013; and 6 2. 7 the Complaint. 8 Plaintiffs properly served the Complaint on November 13, 2012, and Defendants’ Defendants shall have until February 11, 2013, to answer or otherwise respond to Dated: January 9, 2013 Respectfully submitted, 9 /s/________________ Ashwani K. Bhakhri, Esq. Law Offices of Ashwani K. Bhakhri 1299 Bayshore Highway, Suite 208 Burlingame, California 94010 Attorney for Plaintiff 10 11 12 13 Dated: January 9, 2013 Respectfully submitted, 14 /s/________________ Melissa S. Leibman Trial Attorney United States Department of Justice Office of Immigration Litigation, DCS Attorney for Defendants 17 18 UNIT ED S ISTRIC ES D TC AT T RT U O 20 January 10, 2013 Date: _________________ o C. Sper NO 21 22 LI RT seph Hon. Joseph C.e Spero Judg Jo H ER United States Magistrate Judge C A 19 Pursuant to stipulation, IT IS SO ORDERED. R NIA 16 FO 15 N 23 Stipulation RE Extension of Time to Answer F D IS T IC T O R Case No. 12-03867 JCS 2 1 CERTIFICATE OF SERVICE 2 3 4 5 6 7 8 9 10 11 12 13 14 I, Melissa Leibman, the undersigned, certify: I am over the age of eighteen years and not a party to the within action or proceedings; I am a Trial Attorney for the United States Department of Justice and my office is located at 450 5th St. NW, Rm 6022 Washington, D.C., 20001. On January 9, 2013, I caused the STIPULATION for Extension of Time for Defendants to Answer or Otherwise Respond to the Complaint and for Filing, Briefing, and Argument on Plaintiffs’ Anticipated Summary Judgment Motion and [PROPOSED] ORDER to be filed with the Clerk of Court for the United States District Court for the Northern District of California by using the appellate CM/ECF system. I also certify that Ashwani K. Bhakhri, Esq., of the Law Offices of Ashwani K. Bhakhri 1299 Bayshore Highway, Suite 208, Burlingame, California 94010, who has entered his appearance on behalf of Plaintiff, is a registered CM/ECF user and that service will be accomplished by the appellate CM/ECF system. 15 /s/________________ Melissa S. Leibman Trial Attorney United States Department of Justice Office of Immigration Litigation, DCS 16 17 18 Attorney for Defendants 19 20 21 22 23 Stipulation RE Extension of Time to Answer Case No. 12-03867 JCS 3

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