Plascencia-De Haro v. Kelly et al

Filing 13

STIPULATION AND ORDER to continue case management conference and extend time for Defendants to respond to complaint. Case Management Statement due by 7/13/2017. Initial Case Management Conference reset for 7/20/2017 11:00 AM in Courtroom C, 15th Floor, San Francisco. Signed by Judge Laurel Beeler on 06/23/2017. (tmiS, COURT STAFF) (Filed on 6/23/2017)

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CHAD A. READLER
Acting Assistant Attorney General
Civil Division
WILLIAM C. PEACHEY
Director, Office of Immigration Litigation
District Court Section
JEFFREY S. ROBINS
Assistant Director
HANS H. CHEN
Senior Litigation Counsel
U.S. Department of Justice, Civil Division
Office of Immigration Litigation, District Court Section
P.O. Box 868, Washington, DC 20044
Tel: [phone]; Fax: [phone]
[e-mail]
ATTORNEYS FOR DEFENDANTS

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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GLORIA PLASCENCIA-DE HARO,
Plaintiff,

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v.
JOHN F. KELLY, et al.,
Defendants.

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No. C 3:17-cv-02079-LB
STIPULATION TO CONTINUE
CASE MANAGEMENT
CONFERENCE AND TO EXTEND
TIME TO RESPOND TO
COMPLAINT

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Pursuant to Local Rules 6-2 and 7-12, Plaintiff Gloria Plascencia-De Haro

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(“Plaintiff”) and Defendants John F. Kelly, et al. (“Defendants” and collectively

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with Plaintiff, the “Parties”) stipulate as follows:

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This is an immigration case arising under the Administrative Procedure Act,
5 U.S.C. § 701, in which Plaintiff challenges the denial by United States

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STIPULATION
NO. C 3:17-CV-02079-LB

UNITED STATES DEPARTMENT OF JUSTICE, CIVIL DIVISION
OFFICE OF IMMIGRATION LITIGATION
P.O. BOX 868
WASHINGTON, DC 20044
-1202-307-4469

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Citizenship and Immigration Services of Plaintiff’s application for adjustment of

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status to permanent residence.

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Defendants’ deadline to answer or otherwise respond to the Complaint in
this action is currently June 23, 2017.

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On April 14, 2017, the Court entered an Order Setting Initial Case

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Management Conference and ADR Deadlines (“Order”), ECF No. 4. The Order

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scheduled an initial case management conference (“CMC”) for July 13, 2017.

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The Parties have agreed to pursue additional administrative remedies that
may obviate the need for further litigation. The Parties are this day filing a Notice

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of Need for ADR Phone Conference in which they are requesting an Early

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Settlement Conference with a Magistrate Judge. At that Early Settlement

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Conference, the parties intend to discuss the potential administrative remedies

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further with the Magistrate Judge.

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To permit the Parties to do so without burdening them or the Court with

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additional filings or conferences, the Parties respectfully request and stipulate to an

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order continuing the CMC until July 20, 2017. For the same reason, the Parties

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respectfully request and stipulate to an order extending the Parties’ time to answer

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or respond to the Complaint by twenty-one days, from June 23, 2017, until and

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including July 21, 2017.

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Undersigned counsel for Defendants attests he obtained the concurrence in
the filing of the document from the other electronic signatory to this stipulation.
This is the first request for modification of time in this action.

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STIPULATION
NO. C 3:17-CV-02079-LB

UNITED STATES DEPARTMENT OF JUSTICE, CIVIL DIVISION
OFFICE OF IMMIGRATION LITIGATION
P.O. BOX 868
WASHINGTON, DC 20044
-2202-307-4469

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Dated: June 22, 2017

Respectfully submitted,

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LAW OFFICE OF
ROBERT L. LEWIS

CHAD A. READLER
Acting Assistant Attorney General
Civil Division

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/s/ Kevin Michael Crabtree
KEVIN MICHAEL CRABTREE
428 13th Street 7th Floor
Oakland, California 94612
[phone]
[phone] (facsimile)
[e-mail]

WILLIAM C. PEACHEY
Director, Office of Immigration Litigation
District Court Section
JEFFREY S. ROBINS
Assistant Director
/s/ Hans H. Chen
HANS H. CHEN
Senior Litigation Counsel
U.S. Department of Justice, Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Washington, DC 20044
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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ATTORNEYS FOR DEFENDANTS

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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06/23/2017
Dated: ______________________ ___________________________________
HON. LAUREL BEELER
United States Magistrate Judge

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STIPULATION
NO. C 3:17-CV-02079-LB

UNITED STATES DEPARTMENT OF JUSTICE, CIVIL DIVISION
OFFICE OF IMMIGRATION LITIGATION
P.O. BOX 868
WASHINGTON, DC 20044
-3202-307-4469